Case: 4:12-cr-00009-RWS Doc. #: 72 Filed: 06/08/12 Page: 1 of 3 PageID #: 367
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MISSOURI
`EASTERN DIVISION
`
`
`Case. No. 4:12-cr-00009 RWS DDN
`
` )
` )
` )
` )
` )
` )
` )
` )
` )
`
`UNITED STATES OF AMERICA,
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`SANDRA L. BEHE,
`
`
`
`
`
`
`
`
`
`
`
`Defendant.
`
`
`
`
`DEFENDANT’S REQUEST FOR ADDITIONAL TIME TO FILE
`OBJECTIONS TO THE PSR
`
`
`Defendant Sandra L. Behe by her undersigned attorney respectfully requests additional
`
`time to and including June 12, 2012 to file any objections to the Presentence Report (“PSR”). In
`
`support of this motion, Defendant states as follows:
`
`1.
`
`2.
`
`This matter is currently set for sentencing on June 22, 2012.
`
`Pursuant to this Court’s order of May 2, 2012, Defendant’s objections to the
`
`PSR are due on June 8, 2012.
`
`3.
`
`The PSR relates a complex history and raised a number of factual and legal issues
`
`that Defendant has worked to resolve with the U.S. Probation Office and the
`
`U.S. Attorney’s Office. This effort has involved numerous conversations and extensive
`
`correspondence. In a meeting today among undersigned counsel, AUSA Andrew Lay and
`
`Probation Officer Suzann Cross, most, but not all, of these issues were resolved.
`
`4.
`
`Defendant requests additional time to and including Tuesday, June 12, 2012 to
`
`file any objections to the PSR. The additional time is necessary to allow Defendant, who resides
`
`in California, to adequately consult with counsel regarding the June 8 discussions with the U.S.
`
`1
`
`
`
`

`

`Case: 4:12-cr-00009-RWS Doc. #: 72 Filed: 06/08/12 Page: 2 of 3 PageID #: 368
`
`Probation Office and the U.S. Attorney’s Office and to allow her counsel, if necessary, to
`
`prepare any objections to the PSR.
`
`WHEREFORE, Defendant Sandra L. Behe respectfully requests that the Court grant
`
`an extension of time until June 12, 2012 to file any objections to the PSR.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`HAAR & WOODS, LLP
`
`
`
`
`
`
`/s/ Robert T. Haar
`
`Robert T. Haar - #30044MO
`
`1010 Market Street, Suite 1620
`
`St. Louis, Missouri 63101
`
`(314) 241-2224
`
`(314) 241-2227 Telecopier
`
` edmofiling@haar-woods.com
`
`
`
` Attorneys for Defendant Sandra L. Behe
`
`2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Case: 4:12-cr-00009-RWS Doc. #: 72 Filed: 06/08/12 Page: 3 of 3 PageID #: 369
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that on the 8th day of June 2012, the foregoing was filed electronically
`with the Clerk of the Court to be served by operation of the Court’s electronic filing system upon
`the following:
`
`/s/ Robert T. Haar
`
`
`
`
`
`
`
` 
`
`
`
`
`
`3
`
`
`
`Andrew J. Lay
`Assistant United States Attorney
`111 South 10th Street, Suite 20.333
`St. Louis, Missouri 63102
`andrew.lay@usdoj.gov
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.

We are unable to display this document.

HTTP Error 500: Internal Server Error

Refresh this Document
Go to the Docket