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

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams, Suite 201 3 Phoenix, Arizona 85007 4 Telephone: (602) 382-2749 5 GERALD A. WILLIAMS, #013115 Asst. Federal Public Defender 6 Attorney for Defendant [email protected] 7 IN THE UNITED STATES DISTRICT COURT 8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 The defendant, by and through undersigned counsel, respectfully 18 requests that the date for Ms. Flores to self-surrender be extended an additional ten 19 (10) days from the present date of Thursday, November 30, 2006. Additional time 20 is needed to allow Ms. Flores to transfer Social Security benefits for her son issued 21 to Ms. Flores to be transferred to her mother, Wilma Cornett. 22 Assistant U.S. Attorney Darcy Cerow was contacted and stated she has 23 no objection to this additional extension. However, Ms. Cerow indicated she will 24 25 have an objection to any further extension requests. 26 . . . 27 . . . 28 . . . vs. Linda Flores, Defendant. United States of America, Plaintiff, No. CR-02-1153-PHX-ROS SECOND EMERGENCY MOTION TO EXTEND TIME TO SELF-SURRENDER (Third Request) (Expedited Ruling Requested)

Case 2:02-cr-01153-ROS

Document 28

Filed 11/29/2006

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1

It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: November 29, 2006. 4 5 6 7 8 JON M. SANDS Federal Public Defender s/Gerald A. Williams GERALD A. WILLIAMS Asst. Federal Public Defender

Copy of the foregoing transmitted 9 by ECF for filing this 29th day 10 of November, 2006, to: 11 CLERK'S OFFICE United States District Court 12 Sandra Day O'Connor Courthouse 401 W. Washington 13 Phoenix, Arizona 85003 14 DARCY CEROW Assistant U.S. Attorney 15 United States Attorney's Office Two Renaissance Square 16 40 N. Central Avenue, Suite 1200 17 Phoenix, Arizona 85004-4408 18 Copy mailed to: 19 United States Marshal's Office Sandra Day O'Connor Courthouse 20 401 W. Washington Phoenix, Arizona 85003 21 ADELINA BUSTAMANTE 22 United States Probation 23 Sandra Day O'Connor Courthouse 401 W. Washington, Suite 160 24 Phoenix, Arizona 85003 25 LINDA FLORES Defendant 26 27 28
s/T.Gutierrez
\ExtendSelfSurrenderMTN3

Case 2:02-cr-01153-ROS

Document 28

Filed 11/29/2006

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