Free Notice (Other) - District Court of Colorado - Colorado

Case 1:00-cr-00016-RPM

Document 97

Filed 06/10/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 00-CR-00016-RPM

UNITED STATES OF AMERICA, Plaintiff, v. SAMUEL ROBINSON, Defendant. ______________________________________________________________________________ NOTICE OF WITHDRAWAL OF ALLEGATIONS ______________________________________________________________________________ The defendant, through undersigned counsel, and with the concurrence of the Office of the U.S. Attorney and the U.S. Probation Office, gives notice of that the U.S. Probation Office intends to withdraw the fourth and fifth allegations in the amended supervised release violation petition filed April 23, 2008. See Doc. 22.1 The fourth and fifth allegations charge the defendant with law violations that, according to charges filed in El Paso County, Colorado, case 2008M2855, occurred on March 12, 2008. The charges, third degree assault and criminal mischief, are both misdemeanors, and are still pending in El Paso County. When the amended petition was filed on April 23, 2008, a warrant issued, and, on April 24, 2008, the defendant was arrested. See Docs. 82, 83, and 87. On April 29, 2008, a preliminary

Following a revocation hearing held on February 13, 2008, the Court found that allegations 1, 2, and 3 in the original petition were proven. See Docket # 77, Minute Entry. These three allegations are included in the amended petition. The defendant has not been sentenced on them.

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Case 1:00-cr-00016-RPM

Document 97

Filed 06/10/2008

Page 2 of 3

and detention hearing was held. The defendant was ordered detained, and a revocation hearing scheduled in this Court for June 20, 2008. Because the fourth and fifth allegations in the amended petition were the impetus for the issuance of the arrest warrant on April 23, 2008, and resulted in the setting of the revocation hearing on June 20, 2008, the parties wished to bring the fact of their proposed withdrawal to the Court's attention as soon as possible. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Warren R. Williamson Warren R. Williamson Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

Case 1:00-cr-00016-RPM

Document 97

Filed 06/10/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on June 10, 2008, I electronically filed the foregoing NOTICE OF WITHDRAWAL OF ALLEGATIONS with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Robert Brown, Assistant US Attorney email: [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the non-participant's name: Richard Vaccaro(via email) email: [email protected]

Samuel Robinson (via mail) c/o Jefferson County Jail

s/ Warren R. Williamson Warren R. Williamson Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant