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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MISSOURI
`EASTERN DIVISION
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`Case No. 4:12-cr-00009-1 RWS
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`vs.
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`JAMES R. NEWCOMB,
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`Defendant.
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`DEFENDANT’S REQUEST FOR ADDITIONAL TIME TO FILE
`OBJECTIONS TO THE PSR AND FOR A NEW SENTENCING DATE
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`COMES NOW Defendant by his undersigned attorney and respectfully requests
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`additional time to respond to the PSR and consequently also for a new sentencing date. In
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`support of this motion, Defendant states as follows:
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`1. This matter is currently set for sentencing on May 26, 2012.
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`2. The PSR was filed by the U. S. Probation Office on April 20, 2012. However, for
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`some unknown reason, undersigned counsel completly missed its filing and did not
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`realize that it had yet been filed. A response to the PSR was originally due May 4,
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`2012. Not having seen the PSR at that time, defense counsel failed to file a response.
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`3. There are several issues raised in the PSR which Defendant feels are very important
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`to be properly addressed and needs sufficient time to do so.
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`4. As a result of the need for additional time to respond to the PSR, there would need to
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`be an extension of the sentencing date.
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`5. The U.S. Attorney’s Office and the U.S. Probation Office do not object to this
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`request.
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`Case: 4:12-cr-00009-RWS Doc. #: 51 Filed: 05/07/12 Page: 2 of 2 PageID #: 265
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`WHEREFORE, Defendant respectfully requests that sentencing be reset to June 22, 2012
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`and that objections to the PSR be due by June 8, 2012.
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`Respectfully submitted,
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`BY:/s/ James G. Martin
`James G. Martin
`Attorney for James R. Newcomb
`ARMSTRONG TEASDALE LLP
`7700Forsyth Blvd., Suite 1800
`St. Louis, Missouri 63105
`(314) 621-5070
`(314) 552-4874 (facsimile)
`jmartin@armstrongteasdale.com
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on May 7, 2012, this pleading served via electronic filing
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`and United States mail to the following:
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`Jean F. Kintz
`United States Probation Officer
`111 South 10th Street, Suite 2.325
`St. Louis, Missouri 63102
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`Andrew Lay
`Assistant U.S. Attorney
`111 South 10th Street, 20th Floor
`St. Louis, Missouri 63102
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`/s/ James G. Martin
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`12730176_1.DOC
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`2
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