Free Consent to Inspection of PSI - District Court of Colorado - Colorado

Case 1:01-cr-00321-LTB

Document 1155

Filed 01/30/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 01-CR00321-LTB-8 USA, Plaintiff, v. Earnest James Martin (8), et al. Defendants. ________________________________________________________________________ PETITION TO RELEASE PRE-SENTENCING INVESTIGATION REPORT ________________________________________________________________________ Defendant, Earnest J. Martin, (hereinafter, "Martin") by and through his attorneys, Faegre & Benson LLP, hereby petitions this Court to release a copy of his Pre-Sentencing Investigation Report. In support of his Petition, Defendant Martin states: 1. On August 23, 2001 this criminal matter was filed against Defendant Martin for

conspiracy to purchase, manufacture, possess and distribute crack cocaine. 2. As a result of the criminal charge, on October 24, 2002 judgment was entered and

Defendant Martin was sentenced to 41 months of jail time. 3. In sentencing Defendant Martin, this Court ordered the Pre-Sentencing

Investigation Report ("PSI"). This PSI was provided by Defendant Martin's probation officer, Mr. Gary Kruck, on October 16, 2002. Counsel contacted Mr. Kruck to obtain the PSI and was told that he no longer has a copy. 4. The undersigned counsel represents Defendant Martin in a juvenile matter entitled

Earnest J. Martin v. Lendera A. Cox, Juvenile Court, City and County of Denver, State of Colorado, Case No. 98CV3185. In conjunction with the juvenile court matter, it has come to Defendant Martin's attention that portions of his criminal history records may be inaccurate.

Case 1:01-cr-00321-LTB

Document 1155

Filed 01/30/2006

Page 2 of 2

5.

Defendant Martin believes that this Court's PSI report includes true and accurate

history of all criminal offenses. Defendant Martin requests a copy of this PSI report so that he can adequately review and request correction of any and all inaccurate criminal history information in other records and databases. WHEREFORE, Defendant Martin requests that this Honorable Court release his PSI report and for such other relief as this Court deems proper. Dated this 30th day of January, 2006.

_________________________________ Janet Lawler McDaniel FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203-4532 DC Box 21 Telephone: (303) 607-3500 Facsimile: (303) 607-3600 Attorneys for Defendant Earnest J. Martin

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