Free Motion to Reduce Sentence - District Court of Colorado - Colorado

Case 1:01-cr-00321-LTB

Document 1152

Filed 01/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 01-cr-00321-LTB-01 UNITED STATES OF AMERICA, Plaintiff, v. 1. MARK ANTHONY GREENE, Defendant.

GOVERNMENT'S MOTION PURSUANT TO FED.R.CRIM.P. 35(b) FOR REDUCTION OF SENTENCE

COMES NOW the United States of America, by William J. Leone, United States Attorney for the District of Colorado, by and through the undersigned Assistant United States Attorney, Bernard E. Hobson, and pursuant to defendant's cooperation moves this Honorable Court for a further reduction of defendant's sentence below the previously imposed 101 months incarceration pursuant to Rule 35(b). In a series of recent meetings with law enforcement officers as well as through his defense counsel, the defendant submitted substantial additional information and answered additional questions posed to him by the officers concerning his drug activities and sources, as well as with respect to several homicides in the Denver metropolitan area. The defendant also provided important corroborative information which, in the view of the undersigned, warrants the fling of this motion. The United States is satisfied that the defendant has rendered complete and truthful information which corroborated other information already alleged by law enforcement, that

Case 1:01-cr-00321-LTB

Document 1152

Filed 01/20/2006

Page 2 of 3

certain other co-defendants were in possession of large quantities of controlled substances for distribution. The United States values the defendant's information as deserving of a further reduction of the sentence imposed by reducing it by one year to a sentence of 89 months. Wherefore, premises considered the United States respectfully requests that the Court grant this motion and reduce the sentence of the defendant. Respectfully submitted, WILLIAM J. LEONE United States Attorney BY: s/ Bernard E. Hobson BERNARD E. HOBSON Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0203 FAX: (303) 454-0401 E-mail: [email protected] Attorney for Government

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Case 1:01-cr-00321-LTB

Document 1152

Filed 01/20/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 20th day of January, 2006, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification to the following e-mail addresses: Joseph Saint-Veltri, Esq. Email: [email protected] and I hereby certify that I have mailed or served the document or paper to the following nonCM/ECF participants in the manner indicated:

s/ Cathy Palma CATHY PALMA Legal Assistant to BERNARD E. HOBSON Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0401 E-mail: [email protected]

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