Free Motion to Travel - District Court of Colorado - Colorado

Case 1:04-cr-00433-WDM

Document 489

Filed 03/10/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00433-WDM UNITED STATES OF AMERICA, Plaintiff, V. 5. RAFAEL SAENZ ORTIZ ________________________________________________________________________ UNOPPOSED MOTION TO ALLOW OUT OF STATE TRAVEL ________________________________________________________________________ Defendant Rafael Saenz Ortiz moves this court to allow him to travel to on a short trip to Albuquerque Mew Mexico. As grounds for this motion, Mr. Saenz Ortiz states: 1. Mr. Saenz Ortiz was granted bail in this case on October 19, 2004

and is currently on an unsecured bond. 2. Mr Saenz Ortiz has not traveled out of state during the nearly year

and one half that he has been on bond. 3. Mr. Saenz would like to visit his sister who resides in Albuquerque.

She is unable to visit him since she is caring full time for her father in law who is extremely ill. 4. Mr. Saenz Ortiz wishes to leave Denver on March 30, 2006 and

return on the evening of April 4, 2006. He will be traveling by car with his wife and mother in law. He will stay in a motel in the Albuquerque area. He will

Case 1:04-cr-00433-WDM

Document 489

Filed 03/10/2006

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provide all travel details and contact information to his probation officer, Sarah Hoppe before his departure. 5. Counsel has discussed this matter with AUSA Greg Rhodes and

Sarah Hoppe of who advised counsel that they had no objection to the requested travel. Respectfully submitted, s/ Mitchell Baker __________________________ Mitchell Baker Attorney for Defendant Saenz Ortiz 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of March, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail address:

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Mitchell Baker [email protected] [email protected] Richard James Banta [email protected] [email protected];[email protected] Darren Randal Cantor [email protected] Martha Horwitz Eskesen [email protected] Matthew Rodney Giacomini [email protected] [email protected];[email protected] Gregory Allen Holloway [email protected] [email protected];[email protected] Michael Paul Litman [email protected]

Case 1:04-cr-00433-WDM

Document 489

Filed 03/10/2006

Page 3 of 3

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Robert S. McCormick [email protected] [email protected] Lisa Anne Polansky [email protected] Gregory Hayze Rhodes [email protected] [email protected];[email protected] Daniel Joseph Sears [email protected] Harvey Abe Steinberg [email protected] [email protected] Barrett Thomas Weisz [email protected] [email protected]

S/Mitchell Baker __________________________ Mitchell Baker Attorney for Defendant Saenz Ortiz 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 [email protected]