Free Motion to Continue - District Court of Colorado - Colorado

Case 1:00-cr-00083-DBS

Document 48

Filed 12/15/2006

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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 January 9, 2007, in the above-captioned case. In support of this motion, undersigned counsel ("counsel") would show: 1. 2. A violation hearing is currently scheduled for January 9, 2007. Undersigned counsel ("counsel") will be out of the office in Durango, Colorado for

a murder trial before the Honorable Phillip S. Figa in U.S. v. Lang, Case No. 06-cr-00238-PSF from January 8, 2007 through January 12, 2007. 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. Counsel has consulted Ginger of this Court and discussed January 5, 2007 as a possible new court date. Both parties and probation would be available then.

Case 1:00-cr-00083-DBS

Document 48

Filed 12/15/2006

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4.

Robert Brown, the Assistant United States Attorney assigned to this case, does not

oppose this motion. Neither does Probation Officer Sherrie Blake. WHEREFORE, counsel requests that this Honorable Court grant this motion and reset the hearing to January 5, 2007 at 10:00 a.m. 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 48

Filed 12/15/2006

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on December 15, 2006, 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: [email protected] [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: Keith Lynn 895 21 Road Fruita, CO 81521

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 .