Free Motion to Extend Time - District Court of Arizona - Arizona

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Ulises A. Ferragut, Jr. #018773 FERRAGUT & ASSOCIATES, P.C. One Renaissance Square 2 North Central Avenue, Suite 715 Phoenix, Arizona 85004 Tel. (602) 324-5300 Fax. (602) 258-4588 E-Mail: [email protected] Counsel for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America ) ) ) ) ) ) ) ) ) No. CR 02­1179­PHX­PGR No. CV­04­2209­PHX­PGR (MEA) MOVANT'S MOTION FOR EXTENSION OF TIME FOR FILING AMENDED OBJECTIONS TO MAGISTRATE'S REPORT AND RECOMMENDATION

10 Plaintiffs, 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 vs. Carlos Anselmo Moreno, Jr., Defendants.

COMES NOW Movant Carlos A. Moreno, Jr., through undersigned counsel, and hereby moves the Court for an extension of time for submitting the Amended Objections to Magistrate's Report and Recommendation that currently is due on or before April 9, 2007 (pursuant to prior Order of this Court). The Court issued an Order unsealing the file in this case for purposes of permitting review of specific documents, including a transcript which had not been previously produced. Following the Court's Order unsealing the record,

undersigned counsel ordered the transcript, which recently was produced and provided to undersigned counsel on March 27, 2007. Based upon the recent receipt of the essential transcript and the necessity for reviewing that transcript in light of the entire case and potentially requiring

Case 2:02-cr-01179-PGR

Document 138

Filed 04/05/2007

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contact with the Movant, who is in federal custody, undersigned counsel respectfully requests an extension of time for a period of sixty (60) days, from April 9, 2007, to June 8, 2007, in which to submit the defendant's Amended Objections to the Report and Recommendation. RESPECTFULLY SUBMITTED this 5 th day of April, 2007. F ERRAGUT & ASSOCIATES, P.C.

/s/ Ulises A. Ferragut, Jr. Ulises A. Ferragut, Jr. One Renaissance Square 2 North Central Avenue, Suite 715 Phoenix, Arizona 85004 Attorney for Defendant ORIGINAL of the foregoing electronically filed this 5 th day of April, 2007. COPIES of the foregoing mailed or electronically sent this 5 th day of April, 2007, as noted below: Honorable Paul G. Rosenblatt United States District Court District of Arizona 401 West W ashington Phoenix, Arizona 85003 David A. Pimsner Assistant U.S. Attorney U.S. Attorney's Office 40 North Central Avenue, Suite 1200 Phoenix, AZ. 85004 Attorney for United States of America /s/ Ulises A. Ferragut, Jr.

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