Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:00-cr-00455-DBS

Document 128

Filed 03/22/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 00-cr-00455-DBS UNITED STATES OF AMERICA, Plaintiff, v. ANNE ELIZABETH HUENNEKENS, Defendant. and EINSTEIN BAGEL, Garnishee.

MOTION TO DISMISS WRIT OF GARNISHMENT

Plaintiff, United States of America, by its undersigned attorneys, moves this Court for an order to dismiss the writ of garnishment filed June 27, 2006, against the above-named Defendant. As grounds therefor, Plaintiff states: 1. Judgment was entered herein on May 15, 2001, in the amount of $2,740.25 ($100.00 Special Assessment; $2,640.25 - Restitution). 2. A Writ of Garnishment was filed on June 27, 2006 against the Defendant's employer, Einstein Bagel. 3. The garnishment should be dismissed because defendant is no longer employed with this company.

Case 1:00-cr-00455-DBS

Document 128

Filed 03/22/2008

Page 2 of 3

WHEREFORE, Plaintiff requests the Court to dismiss the Writ of Garnishment filed on June 27, 2006 in the above captioned case. Respectfully submitted, TROY A. EID United States Attorney Dated: March 21, 2008 By: s/ Lisa A. Christian LISA A. CHRISTIAN Assistant U. S. Attorney 1225 17th Street, Suite 700 Denver, CO 80202 303-454-0100 Attorneys for Plaintiff United States of America

Case 1:00-cr-00455-DBS

Document 128

Filed 03/22/2008

Page 3 of 3

CERTIFICATE OF MAILING I hereby certify that on March 22, 2008 I electronically filed the foregoing with the Clerk of the court using the ECF system which will send notification of such filing to the following email addresses: [email protected] In addition, I hereby certify that I have mailed or faxed the document to the following non CM/ECF participants: Einstein Bagel Attn: Ann Shans - payroll 1675 Broadway, # 1200 Denver, CO 80202 Anne Elizabeth Huennekens 1075 Sherman Street, # 105 Denver, CO 80203

S/ Lisa A. Christian Office of the U.S. Attorney