Case 2:07-cr-20073-CM Document 162 Filed 07/01/10 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KANSAS

UNITED STATES OF AMERICA,

Plaintiff,

vs. Case No. 07-CR-21024-CM

08-CR-20105-CM
GUY NEIGHBORS, 07-CR-20073-CM
Defendant.

MOTION FOR EXTENSION OF TIME TO FILE SELL MOTION

Defendant Guy Neighbors, by and through his counsel, hereby moves this Honorable

Court for an extension of time of one week in which to file any motions concerning the

application of the United States Supreme Court’s decision in United States v. Sell, 539 U.S. 166

(2003). Defendant’s motion is currently due July 2, 2010, and Defendant seeks an extension of

one week, up to and including July 9, 2010. In further support of this Motion, Defendant states

as follows:

1. At a hearing held on June 23, 2010, this Court granted Defendant’s request for leave to

submit briefing under the Supreme Court’s decision in Sell. The Court gave Defendant a

deadline of July 2, 2010.

2. To permit counsel sufficient time to visit with her client and research the applicable

law, Defendant requests an extension of one week (7 days) in which to submit his Sell motion, up

to and including July 9, 2010.

3. Counsel for the government has been contacted and states she does not oppose the

granting of this motion.

4. This motion for extension is not for the purpose of delay, but rather to allow defense
 Case 2:07-cr-20073-CM Document 162 Filed 07/01/10 Page 2 of 2

counsel a sufficient opportunity to communicate with her client, research the applicable law and

submit an appropriate pleading.

5. The granting of this motion will not affect any other deadline in this case and will not

cause any delay, as Defendant understands that, based on the Court’s and Dr. Lucking’s schedule,

the anticipated hearing on Sell and other matters will not be held until July 27, 2010.

WHEREFORE, based on the above and foregoing, Defendant respectfully requests an

extension of one week, up to and including July 9, 2010, in which to file his Sell motion.

Respectfully Submitted,

/s/ Melanie S. Morgan

Melanie S. Morgan, KS No. 16088
MORGAN PILATE LLC
142 N. Cherry
Olathe, KS 66061
Telephone: 913-829-6336
Facsimile: 913-829-6446
Attorney for Guy Neighbors

CERTIFICATE OF SERVICE

I, Melanie S. Morgan, do certify that a true and accurate copy of the foregoing motion

was served electronically pursuant to the ECF system on all counsel of record on this 1st day of

July, 2010.
/s/ Melanie S. Morgan