Free Motion to Continue - District Court of Colorado - Colorado

Case 1:01-cr-00359-WYD

Document 361

Filed 01/09/2007

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case Number 01-cr-00359-WYD UNITED STATES OF AMERICA, Plaintiff, v. 2. BRAULIO MEDINA-GARCIA, Defendant

MOTION TO CONTINUE SENTENCING

The Defendant, Braulio Medina-Garcia, by and through his attorney, Harvey A. Steinberg, of the law firm of Springer and Steinberg, P.C., hereby moves this Court for an Order continuing the Sentencing Hearing presently set on January 10, 2007. AS GROUNDS THEREFORE, the Defendant states as follows: 1. 2. This matter is set for Sentencing on January 10, 2007, at 9:00 a.m. Undersigned counsel is currently in a vehicular homicide Jury Trial in Douglas

County District Court (People v. Tri Nguyen 2005CR177). The Douglas County matter was to be resolved short of going to trial. However, the parties are proceeding with trial and undersigned counsel is not available. 3. Undersigned counsel's office left a message with Assistant United States

Attorney Jaime Pena regarding his position on this matter. As of the filing of this motion, his position is' unknown. WHEREFORE, the Defendant respectfully requests this motion be granted.

Case 1:01-cr-00359-WYD

Document 361

Filed 01/09/2007

Page 2 of 2

DATED this 9th day of January, 2007.

Respectfully submitted, s/Harvey A. Steinberg Attorney for Braulio Medina-Garcia Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

CERTIFICATE OF SERVICE I hereby certify that on January 7, 2007, I electronically filed the foregoing MOTION TO CONTINUE SENTENCING with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Jaime A. Pena Email: [email protected]

s/Brenda Rodriguez For Harvey A. Steinberg Attorney for Braulio Medina-Garcia Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]