Case 3:07-cr-00289-M Document 1734

Filed 05/31/11

Page 1 of 3 PageID 34322

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION _______________________________ UNITED STATES OF AMERICA V. RONALD W. SLOVACEK (12) § § § NO. 3:07-CR-289-R

DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME FOR DEFENDANT TO REPORT TO THE DESIGNATED INSTITUTION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW the Defendant, RONALD W. SLOVACEK, through undersigned counsel and files this his Unopposed Motion to Extend Time in which the Defendant must report to the designated federal correctional institution for service of his sentence. In support of said Motion, the Defendant would show unto the Court as follows: I. The Judgment and Sentence in this case requires the Defendant to report to the designated federal correctional institution on June 7, 2011 to begin service of his sentence. II. On May 25, 2011, the Defendant underwent arthroscopic surgery on his right knee for an injury that occurred within a week prior to sentencing on April 22, 2011. The Defendant gave the injury time to see if it would heal. It did not. In the first part of May he saw Dr. John D. Evanich, M.D., an orthopedic surgeon who, after examinations and an MRI of the knee, advised surgery as soon as possible. The surgery was performed by Dr. Evanich on May 25, 2011 at the Baylor Surgery Center in Lewisville, Texas.

UNOPPOSED M OTION TO EXTEND TIM E FOR DEFENDANT TO REPORT TO THE DESIGNATED INSTITUTION- Page 1

Case 3:07-cr-00289-M Document 1734

Filed 05/31/11

Page 2 of 3 PageID 34323

While the surgery was successful in repairing the injury, the extent of the injury was greater than expected. Dr. Evanich has prescribed four (4) to six (6) weeks of immediate rehabilitation in order for the knee to properly heal. The required rehabilitation would be completed by June 22, 2011 to June 24, 2011. The Defendant is requesting an extension of time within which to report to the designed federal correctional institution to Tuesday, June 28, 2011 in order to allow him to get his knee rehabilitated and well before reporting to start his prison sentence. III. The Government, through Assistant United States Attorney Chad Meachum, does not oppose the granting of this Motion. WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully requests that this Honorable Court grant this motion to extend the time for the Defendant to report to the designated federal correctional institution to June 28, 2011. Respectfully submitted, BURLESON, PATE & GIBSON, L.L.P. /s/ Michael P. Gibson ____________________________________ MICHAEL P. GIBSON Texas Bar Card 07871500 900 Jackson Street, Suite 330 Dallas, Texas 75202 Telephone: (214) 871-4900 Facsimile: (214) 871-7543 COUNSEL FOR DEFENDANT RONALD W. SLOVACEK

UNOPPOSED M OTION TO EXTEND TIM E FOR DEFENDANT TO REPORT TO THE DESIGNATED INSTITUTION- Page 2

Case 3:07-cr-00289-M Document 1734

Filed 05/31/11

Page 3 of 3 PageID 34324

CERTIFICATE OF CONFERENCE This is to certify that on the 27th day of May, 2011, undersigned counsel conferred with Chad Meachum, Assistant United States Attorney, and is authorized to state that the Government does not oppose this Motion. /s/ Michael P. Gibson ____________________________________ MICHAEL P. GIBSON CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing motion was delivered by ECF filing to Chad Meacham and Stephen Fahey, Assistant United States Attorneys, 1100 Commerce, 3rd floor, Dallas, TX 75242, and by electronic mail to Juliana Moore, United States Probation Office, 1100 Commerce, 13th floor, Dallas, TX 75242, on this the 31st day of May, 2011. /s/ Michael P. Gibson ___________________________________ MICHAEL P. GIBSON

UNOPPOSED M OTION TO EXTEND TIM E FOR DEFENDANT TO REPORT TO THE DESIGNATED INSTITUTION- Page 3

Sign up to vote on this title
UsefulNot useful