Free Motion for Decrease for Acceptance of Responsibility - District Court of Colorado - Colorado

Case 1:01-cr-00350-WYD

Document 453

Filed 12/13/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Hon. Wiley Y. Daniel Criminal Case No. 01-cr-00350-WYD-01 UNITED STATES OF AMERICA, Plaintiff, v. 1. JASON M. PRICE, Defendant.

GOVERNMENT'S MOTION AND NOTICE OF SENTENCING FACTORS

The United States of America, by Troy A. Eid, United States Attorney for the District of Colorado, and through Gregory H. Rhodes, Assistant United States Attorney, hereby submits the Government's motion requesting that the Court grant the defendant a three level decrease in the offense level for the timely acceptance of responsibility and states to the Court in regard to the defendant's sentencing, as follows: 1. Pursuant to the Amendments to the Sentencing Guidelines, effective April 30, 2003, the United States must move the Court if, in the opinion of the Government, the defendant is deserving of the three level decrease for acceptance of responsibility. The Government has determined that the defendant is deserving of the three-level reduction in the above captioned case.

Case 1:01-cr-00350-WYD

Document 453

Filed 12/13/2007

Page 2 of 3

2. Therefore, the Government hereby respectfully notifies the Court "that the defendant has assisted authorities in the investigation [and] prosecution of his own misconduct by timely notifying the authorities of his intention to enter a plea of guilty." U.S.S.G. § 3E1.1(b). 3. Accordingly, the Government hereby enters its motion for the Court to grant the defendant a three-level decrease in the offense level. Respectfully submitted, TROY A. EID United States Attorney

By:

s/ Gregory H. Rhodes GREGORY H. RHODES Assistant U.S. Attorney 1225 17th Street # 700 Denver, Colorado 80202 Phone: (303) 454-0100 Fax: (303) 454-0401 E-Mail: [email protected] Attorney for Government

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Case 1:01-cr-00350-WYD

Document 453

Filed 12/13/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 13 th day of December, 2007, I electronically filed the foregoing GOVERNMENT'S MOTION AND NOTICE OF SENTENCING FACTORS with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address: John M. Richilano [email protected],[email protected],[email protected] and I hereby certify that I have mailed or served the document or paper to the following non- CM/ECF participants in the manner indicated: None

s/ Diana Brown DIANA BROWN Legal Assistant United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0409 E-mail: [email protected]