Free Motion to Continue - District Court of Colorado - Colorado

Case 1:01-cr-00359-WYD

Document 324

Filed 03/23/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case Number 01-cr-00359-WYD UNITED STATES OF AMERICA, Plaintiff, v. 2. BRAULIO MEDINA-GARCIA, Defendant

UNOPPOSED MOTION TO CONTINUE JURY TRIAL

The Defendant, Braulio Medina-Garcia, by and through his attorney, Harvey A. Steinberg, of the law firm of Springer and Steinberg, P.C., hereby moves this Court for an Order continuing the Jury Trial presently set for April 17, 2006. AS GROUNDS THEREFORE, the Defendant states as follows: 1. 2. This matter is set for Jury Trial on April 17, 2006. Unfortunately, another case has been set on that same date involving what has

been referred to as the "GKI" Indictment. 3. 4. That Indictment initially involved almost thirty defendants and their lawyers. Obviously, because of the great number defendants and lawyers in setting that

case, Judge Nottingham was unable to accommodate the various lawyers schedules. 5. Although a number of Defendants have agreed to dispositions, there are still

approximately seventeen co-defendants that are still scheduled for trial on April 17, 2006.

Case 1:01-cr-00359-WYD

Document 324

Filed 03/23/2006

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5.

As a result, the Defendant is asking this Court to continue this matter. The parties

have pre-cleared August 21, 2006, for trial. That date is available on both lawyers calendars, as well as the Court's calendar. 6. The government has no objection to this motion being granted. WHEREFORE, both parties request this motion be granted. DATED this 23rd day of March, 2006.

Respectfully submitted, s/Harvey A. Steinberg Attorney for Braulio Medina-Garcia Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone

Case 1:01-cr-00359-WYD

Document 324

Filed 03/23/2006

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CERTIFICATE OF SERVICE I hereby certify that on March 23, 2006, I electronically filed the foregoing UNOPPOSED MOTION TO CONTINUE JURY TRIAL with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Jaime A. Pena Email: [email protected]

s/Jan Cooley For Harvey A. Steinberg Attorney for Braulio Medina-Garcia Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]