Free Motion for Bond - District Court of Colorado - Colorado

Case 1:04-cr-00403-LTB

Document 618

Filed 03/14/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00403-LTB-6 UNITED STATES OF AMERICA, Plaintiff, v. 6. JAIME ARMENDARIZ-MARTINEZ, Defendant. ______________________________________________________________________________ MOTION FOR RELEASE ON BOND ______________________________________________________________________________

COMES NOW Lisabeth P. Castle, CJA attorney at law, respectfully moves this court for a hearing to set a bond pursuant to U.S.C. § 3142 and hereby sets forth as follows in support of this motion: 1. Mr. Armendariz was arrested in this matter in August of 2005. 2. Mr. Armendariz is a legal resident. He has been a legal resident since 1987. 3. Mr. Armendariz has significant ties within the United States. His immediate family lives in El Paso Texas. His immediate family includes his wife, four children and two grandchildren. His wife and children are also legal permanent residents. His youngest child and his grandchildren are citizens of the United States. 4. His wife continues to live at the same home they have shared for 8 years. This property is the property of Mr. Armanedariz and his family. The family continues to pay the mortgage on this property and are willing to use any equity as collateral.

Case 1:04-cr-00403-LTB

Document 618

Filed 03/14/2006

Page 2 of 3

5. Mr. Armendariz became a target of this investigation at the tail end. His name surfaced approximately six months prior to the end of the investigation. 6. Agents for the FBI conducted a search of the Defendant's home in 2004. No warrant was in effect for the defendant at the time. Mr. Armendariz was not present during the search however his son did consent to a search. 7. After the search of his home Mr. Armendariz did not flee the country. 8. Mr. Armendariz respectfully submits that there is a combination of factors that will assure his appearance and assure the safety of the community. 9. The government represented by Ms. Stephanie Podolak objects to this motion. WHEREFORE, Defendant Jaime Armendariz-Martinez respectfully requests a hearing in this matter. Dated this 14th day of March, 2006 Respectfully submitted,

S/Lisabeth Perez Castle Lisabeth Perez Castle Castle & Castle, P.C. Counsel for Mr. Jaime Armendariz-Martinez 1860 Race Street Denver, CO 80206 CERTIFICATE OF SERVICE I hereby certify that on this 14TH day of March 2006, a true and correct copy of JAIME ARMENDARIZ-MARTINEZ MOTION FOR RELEASE ON BOND via the CM/ECF system properly addressed to the following: Richard J. Banta ([email protected]) Thomas Carberry ([email protected]) James A. Castle ([email protected]) Robert J. Driscoll ([email protected]) Charles W. Elliot ([email protected])

Case 1:04-cr-00403-LTB

Document 618

Filed 03/14/2006

Page 3 of 3

Martha H. Eskesen ([email protected]) Jennifer L. Gedde ([email protected]) Walter L. Gerash ([email protected]) Richard Kornfeld ([email protected]) Forrest W. Lewis ([email protected]) Donald L. Lozow ([email protected]) Neil E. MacFarlane ([email protected]) Jeffrey S. Pagliuca ([email protected]) Lynn Pierce ([email protected]) Stephanie Podolak ([email protected]) Scott T. Poland ([email protected]) Daniel T. Recht ([email protected]) Michael G. Root ([email protected]) James F. Scherer ([email protected]) Harvey A. Steinberg ([email protected]) John F. Sullivan, III ([email protected]) Richard L. Tegtmeier ([email protected]) Jonathan S. Willett ([email protected]) Earl S. Wylder ([email protected]) Mitchell Baker ([email protected])

and the following copies via U.S. Mail, postage prepaid: Angelica B. Carreon, Esq. 210 North Campbell El Paso, TX 79901 Lucia C. Gallery Isaacson Rosenbaum, P.C. 633-17th Street #2200 Denver, CO 80202 Anita M. Springsteen 5000 West 13th Avenue Denver, CO 80204

S/Stacy Trujillo