Free Response to Motion - District Court of Colorado - Colorado

Case 1:01-cr-00386-ZLW

Document 28

Filed 11/28/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action Nos. 01-cr-00386-ZLW UNITED STATES OF AMERICA, Plaintiff, v. 1. HAROLD ALLEN HUGHES, Defendant. ______________________________________________________________________________ GOVERNMENT RESPONSE TO MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE (DOCKET #27) ______________________________________________________________________________ THE UNITED STATES, by United States Attorney Troy A. Eid and Assistant United States Attorney Guy Till, (Government) respectfully submits this response to the defendant's motion for early termination of supervised release. The Government respectfully submits that the motion should be denied and states as follows: 1. The defendant's conviction in this case arises in relation to a pattern of conduct involving serious federal criminal activity by the defendant and defendant's associates. 2. It is in the best interest of the public to maintain supervision over the defendant. 3. The Government has received no adverse reports from U.S. Probation concerning the defendant's behavior or adjustment; the Government is optimistic that the defendant will continue to do well and benefit from supervised release.

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Case 1:01-cr-00386-ZLW

Document 28

Filed 11/28/2006

Page 2 of 3

4. The Government opposes the defendant's motion for early termination of supervised release. Respectfully submitted this 28th day of November, 2006.

TROY A. EID UNITED STATES ATTORNEY

By: s/Guy Till GUY TILL Assistant U.S. Attorney 1225 17th Street, Suite 700 Denver, Colorado 80202 Telephone: 303-454-0100 Fax: 303-454-409 [email protected] Assistant United States Attorney

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Case 1:01-cr-00386-ZLW

Document 28

Filed 11/28/2006

Page 3 of 3

CERTIFICATE OF MAILING I hereby certify that on this 28th day of November, 2006, a true and correct copy of the foregoing GOVERNMENT RESPONSE TO MOTION FOR EARLY TERMINATION OF SUPERVISED RELEASE (DOCKET #27) was electronically filed with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following parties' email addresses: Peter R. Bornstein, Esq. [email protected] Neil M. Schuster, Esq. [email protected] Jeffrey R. Edelman, Esq. [email protected] Joseph Saint-Veltri, Esq. [email protected]

and I hereby certify that I have mailed or served the document or paper to following non CM/ECF participants in the manner (mail, hand delivery, etc.) indicated by the non-participant's name: U.S.P.O. Gary Phillips

s/Debbie Azua-Dillehay DEBBIE AZUA-DILLEHAY Legal Assistant to Guy Till United States Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 303-454-0100 303-454-0409(fax) [email protected]

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