Free Motion to Continue - District Court of Colorado - Colorado

Case 1:00-cr-00083-DBS

Document 56

Filed 06/20/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 00-cr-00083-DBS UNITED STATES OF AMERICA, Plaintiff, v. KEITH ANSON LYNN, Defendant. ______________________________________________________________________________ MOTION TO RESET SUPERVISED RELEASE VIOLATION HEARING ______________________________________________________________________________ The Defendant, by and through court appointed counsel, Assistant Federal Public Defender Edward R. Harris, respectfully requests this Honorable Court to reset the violation hearing currently set for July 5, 2007, in the above-captioned case. In support of this motion, undersigned counsel ("counsel") states that: 1. 2. A violation hearing is currently scheduled for July 5, 2007. Undersigned counsel ("counsel") is scheduled on July 5, 2007 for an all day

suppression hearing before the Honorable Walker D. Miller in U.S. v. Creighton, Case No. 06-cr00372-WDM. 3. Counsel requests this Honorable Court to reschedule the currently scheduled hearing

and reset it the to a date and time at which he can be present. 4. Neither Robert Brown, the Assistant United States Attorney assigned to this case, nor

Probation Officer Sherrie Blake oppose this motion.

Case 1:00-cr-00083-DBS

Document 56

Filed 06/20/2007

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WHEREFORE, counsel requests that this Honorable Court grant this motion and reset the hearing. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Edward R. Harris Edward R. Harris 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-00083-DBS

Document 56

Filed 06/20/2007

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on June 20, 2007 I electronically filed the foregoing MOTION TO RESET SUPERVISED RELEASE VIOLATION HEARING 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 United States Attorney [email protected]

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant via U.S. Mail: Sherrie Blake, United States Probation Officer [email protected]

Keith Lynn (by mail) c/o Mesa County Community Corrections 6590 South Avenue Grand Junction, CO 81501

s/ Edward R. Harris Edward R. Harris 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 .