Motion for Extension of TIME to Respond to Defendant's Motion by USA as to Aaron Ashcraft — USA v. Ashcraft (Dkt. 47, E.D. Cal.)

Record facts

U.S. District Court for the Eastern District of California · No. 2:22-cr-00087-KJM · Doc. 47 · 2024-03-27 · Docket on CourtListener

Full text

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 GOVERNMENT’S MOTION FOR EXTENSION OF TIME 
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PHILLIP A. TALBERT 
United States Attorney 
 
MATTHEW THUESEN 
Assistant United States Attorney 
501 I Street, Suite 10-100 
Sacramento, CA 95814 
Telephone:  (916) 554-2700 
Facsimile:   (916) 554-2900  
 
 
Attorneys for Plaintiff 
United States of America 
 
 
IN THE UNITED STATES DISTRICT COURT 
 
EASTERN DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
 
                                               Plaintiff, 
 
                                     v. 
 
AARON ASHCRAFT, 
 
                                              Defendant. 
 
 
 
CASE NO.  2:22-CR-00087-KJM 
 
GOVERNMENT’S MOTION FOR AN 
EXTENSION OF TIME 
 
The United States of America, by and through its counsel, Phillip A. Talbert, United States 
Attorney, and Matthew Thuesen, Assistant United States Attorney, hereby requests an extension to April 
17, 2024, in which to file its response or opposition to the defendant’s pro se motion for reconsideration 
of the denial of compassionate release pursuant to 18 U.S.C. § 3582(c)(1)(A).  Docket No. 46.  This 
motion is based on the attached declaration of Assistant United States Attorney Matthew Thuesen. 
 
 
Dated:  March 27, 2024 
By: 
 
PHILLIP A. TALBERT 
United States Attorney 
 
 
/s/ Matthew Thuesen 
 
MATTHEW THUESEN 
Assistant United States Attorney 
 
 
 
 
Case 2:22-cr-00087-KJM     Document 47     Filed 03/27/24     Page 1 of 3

 
 
 
 
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DECLARATION 
DECLARATION 
I, Matthew Thuesen, declare as follows: 
1. 
I am an Assistant United States Attorney for the Eastern District of California and am 
familiar with the facts described below. 
 
 
2. 
On March 19, 2024, the defendant filed a pro se motion for reconsideration of the denial 
of his compassionate release motion. The motion was docketed on March 20, 2024.  Docket No. 46.  
Pursuant to Local Rule, the government’s response is due on March 27, 2024.    
3. 
I am aware personnel from the office of the undersigned have requested necessary 
updated documents from the Bureau of Prisons pertaining to Ashcraft.  Those records have not yet been 
received.  Since the enactment of the First Step Act, document requests take longer to receive than they 
previously did. Undersigned counsel also needs additional time to fully evaluate the records Ashcraft 
attached to his motion for reconsideration. Additionally, undersigned counsel has leave scheduled.  
4. 
For the reasons stated above, the government asks this Court for an extension to April 17, 
2024, to file its response to Ashcraft’s pro se motion.  This will allow time to analyze the relevant 
documents, review the law governing this case, and draft an appropriate response.   
I declare under the penalty of perjury that the foregoing is true and correct to the best of my 
knowledge.   
    Executed this 27th day of March 2024. 
 
 
 
/s/ Matthew Thuesen 
 
MATTHEW THUESEN 
Assistant United States Attorney 
 
 
 
 
 
 
 
 
 
 
 
Case 2:22-cr-00087-KJM     Document 47     Filed 03/27/24     Page 2 of 3

 
 
 
 
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CERTIFICATE OF SERVICE BY MAIL 
The undersigned hereby certifies that he/she is an employee in the Office of the United States 
Attorney for the Eastern District of California and is a person of such age and discretion to be 
competent to serve papers. 
That on March 27, 2024, a copy of the GOVERNMENT’S MOTION FOR AN EXTENSION 
OF TIME and PROPOSED ORDER was served by placing said copy in a postpaid envelope addressed 
to the person(s) hereinafter named, at the place(s) and address(es) stated below, which is/are the last 
known address(es), and by depositing said envelope and contents in the United States Mail at 
Sacramento, 
California. Addressee: 
Aaron Ashcraft 
#00025-510 
FCI-SHERIDAN 
P.O. Box 6000 
Sheridan, OR 97378  
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ C. Buxbaum 
  
 
 
 
 
 
 
 
 
C. BUXBAUM 
 
 
 
Case 2:22-cr-00087-KJM     Document 47     Filed 03/27/24     Page 3 of 3

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