Free Motion to Travel - District Court of Colorado - Colorado

Case 1:01-cr-00321-LTB

Document 1159

Filed 02/10/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 01-cr-00321-B-11 UNITED STATES OF AMERICA, Plaintiff, v. 11. MICHAEL JOSEPH FROE, Defendant.

MOTION TO ALLOW TRAVEL FOR EMPLOYMENT PURPOSES ______________________________________________________________________________ The Defendant, Michael Joseph Froe, by and through his court-appointed counsel, Richard K. Kornfeld of Recht & Kornfeld, P.C., respectfully moves this Court to enter an Order allowing Defendant to travel to Phoenix, Arizona from February 13 to March 10, 2006, for employment purposes. In support of said Motion, the Defendant states as follows: 1. Defendant presently is on probation and, according to Probation Officer John

Marshall, is in full compliance. 2. As the Court may recall, the Defendant is a professional painter whose services

are in great demand. 3. Defendant recently was granted the opportunity to work on behalf of Colorado

Paint Pros, Inc., an entity that has acquired several painting contracts with Wal-Mart stores located, inter alia, in Phoenix, Arizona. Colorado Paint Pros would like to send the Defendant to assist with its contract in Phoenix, Arizona. That would require Defendant to be living and working in the Phoenix area from February 13 to March 10, 2006.

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Case 1:01-cr-00321-LTB

Document 1159

Filed 02/10/2006

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4.

Future out of state contracts are also available to the Defendant through Colorado

Paint Pros, Inc. See letter from Colorado Paint Pros, Inc. dated February 8, 2006, and attached hereto as Exhibit A. 5. On February 10, 2006, undersigned counsel conferred with Probation Officer Mr. Marshall indicated that, while Mr. Froe has been in

Marshall regarding this request.

compliance, the Probation Department objected to this request as it would require Defendant to be out of Colorado for too long a period of time. WHEREFORE, for the reasons stated herein, Defendant respectfully requests that this Court enter an Order allowing him to travel to Phoenix, Arizona from February 13 to March 20, 2006. Respectfully submitted, RECHT & KORNFELD, P.C. s/Richard K. Kornfeld RICHARD K. KORNFELD Attorney for Defendant Froe 1600 Stout St., Suite 1000 Denver, Colorado 80202 (303) 573-1900 Fax: (303) 446-9400 [email protected]

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Case 1:01-cr-00321-LTB

Document 1159

Filed 02/10/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby swear and affirm that on this 10th day of February, 2006, I electronically filed the foregoing Motion to Allow Travel for Employment Purposes with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: Wayne Campbell Assistant U.S. Attorney Felix Garcia Attorney for Greene (1) James Castle Attorney for Shoeboot (2) Dennis Hartley Anthony L. Joseph Attorneys for Cook (3) Pamela Mackey Haddon, Moran, Foreman, P.C. Attorney for Oliver (4) C. Bradley Calbo Attorney for Mack (5) Ronald Gainor Attorney for Shaw (6) Barrett Weisz Attorney for Brown (7) Janet L. McDaniel Robert S. Berger Attorneys for Martin (8) Randy S. Reish Attorney for Hall (9) Peter R. Bornstein Thomas J. Hammond Attorneys for Coleman (10) James S. Covino John S. Tatum Attorneys for Oliver (12) Wade H. Eldridge Attorney for Washington (13) Philip W. Ogden Attorney for Wedgeworth (14) Edward A. Pluss Attorney forWhittiker (15) Scott T. Poland Attorney for Nichols (16) Anthony L. Joseph Dennis W. Hartley Attorneys for Perkins (17)

And the following via United States Mail, postage prepaid to: John Marshall Senior Probation Officer 1961 Stout Street, Suite 525 Denver, CO 80294 s/Michael Shomler Michael Shomler

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