Free Motion for Decrease for Acceptance of Responsibility - District Court of Colorado - Colorado

Case 1:04-cr-00433-WDM

Document 580

Filed 11/27/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00433-WDM UNITED STATES OF AMERICA, Plaintiff, v. 1. JORGE LUIS CORONA, Defendant.

GOVERNMENT'S MOTION FOR DEFENDANT TO RECEIVE THE THIRD LEVEL FOR ACCEPTANCE OF RESPONSIBILITY UNDER U.S.S.G. §3E1.1(b)

COMES NOW, the United States of America, by and through its undesigned Assistant United States Attorney for the District of Colorado, and hereby moves, pursuant to the provisions of §3E1.1(b) of the Sentencing Guidelines, and application note 6 thereto, that this defendant receive a 3-level reduction for acceptance of responsibility on the grounds that the defendant timely notified the Government of her decision to enter a guilty plea and fully advised the Government of the nature of her own misconduct, thereby permitting the Government to avoid preparing for trial and permitting the Government and this Court to allocate their resources efficiently. Respectfully submitted this 27TH day of November, 2006, TROY A. EID UNITED STATES ATTORNEY

By: s/Gregory H. Rhodes GREGORY H. RHODES Assistant U.S. Attorney U.S. Attorney's Office 1225 17th St., Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Fax: (303) 454-0401 E-mail: [email protected] Attorney for Government

Case 1:04-cr-00433-WDM

Document 580

Filed 11/27/2006

Page 2 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 27TH day of November, 2006, I electronically filed the foregoing GOVERNMENT'S MOTION FOR DEFENDANT TO RECEIVE THE THIRD LEVEL FOR ACCEPTANCE OF RESPONSIBILITY UNDER U.S.S.G. §3E1.1(b) with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: Harvey Abe Steinberg [email protected] Matthew Rodney Giacomini [email protected] Barrett Thomas Weisz [email protected] Robert S. McCormick [email protected] Martha Horwitz Eskesen [email protected] Mitchell Baker [email protected] Lisa Anne Polansky [email protected] Daniel Joseph Sears [email protected] Richard James Banta [email protected] Darren Randal Cantor [email protected]

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Case 1:04-cr-00433-WDM

Document 580

Filed 11/27/2006

Page 3 of 3

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the matter indicated by the non-participant's name:

s/ Debbie Azua-Dillehay DEBBIE AZUA-DILLEHAY Legal Assistant to Gregory H. Rhodes Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0409 E-mail: [email protected]

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