Free Motion to Continue - District Court of Colorado - Colorado


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Date: December 14, 2006
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State: Colorado
Category: District Court of Colorado
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Case 1:01-cr-00359-WYD

Document 357

Filed 12/14/2006

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

UNOPPOSED 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 December 22, 2006. AS GROUNDS THEREFORE, the Defendant states as follows: 1. 2. This matter is set for Sentencing on December 22, 2006. Undersigned counsel has been ordered to attend a Re-Sentencing Hearing in the

United States District Court of Nebraska (United States of America v. Jose Aguirre-Burciaga, Case No. 00-cr-00293-JFB). As the Court can see, the matter in Nebraska has been pending since 2000 and will be concluded on December 22, 2006. 3. Undersigned counsel's office spoke to Assistant United States Attorney Jaime

Pena and he does not object to this request. WHEREFORE, the Defendant respectfully requests this motion be granted. DATED this 14th day of December, 2006.

Case 1:01-cr-00359-WYD

Document 357

Filed 12/14/2006

Page 2 of 2

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 December 14, 2006, I electronically filed the foregoing UNOPPOSED 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]