Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cr-00403-LTB

Document 764

Filed 05/26/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00403-LTB UNITED STATES OF AMERICA, Plaintiff, v. 14. BARBARA ZAPATA, Defendant.

JOINT MOTION TO POSTPONE CHANGE OF PLEA HEARING

AND NOW COMES THE UNITED STATES OF AMERICA, WILLIAM J. LEONE, UNITED STATES ATTORNEY, by Stephanie Podolak, Assistant U.S. Attorney, jointly with the defendant BARBARA ZAPATA, by and through her counsel, Walter Gerash, Esq., and respectfully requests that the Court postpone the Change of Plea hearing for the defendant which is currently scheduled for June 2, 2006, and re-set the hearing for the week of June 26, 2006. this motion, the parties state as follows. 1. The parties are working on a resolution of this As grounds for

matter which involve complex issues of testimony and forfeiture. Those issues have not yet been completely resolved. The parties

intend to meet the week of May 30, 3006, but do not believe that those issues can be fully resolved, and a plea agreement drafted, by June 2, 2006.

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Case 1:04-cr-00403-LTB

Document 764

Filed 05/26/2006

Page 2 of 3

2.

In addition, counsel for the defendant is involved

in a murder trial which is expected to begin June 5, 2006, and last for three weeks. WHEREFORE, the parties jointly request that the Change of Plea Hearing be vacated and be re-set for the week of June 26, 2006, which will be before the next pre-trial conference in the case. RESPECTFULLY SUBMITTED: WILLIAM J. LEONE UNITED STATES ATTORNEY DISTRICT OF COLORADO By: s/Stephanie Podolak Stephanie Podolak Assistant United States Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO. 80202 Telephone (303) 454-0309 Fax (303) 454-0401 [email protected] Attorney For Government

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Case 1:04-cr-00403-LTB

Document 764

Filed 05/26/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 26thth day of May, 2006, I electronically filed the foregoing JOINT MOTION TO POSTPONE CHANGE OF PLEA HEARING with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Walter Gerash [email protected]

s/Joyce Hegge JOYCE HEGGE Legal Assistant to Stephanie Podolak U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone: (303) 454-0106 Fax: (303) 454-0401 E-mail: [email protected]

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