Free Motion to Travel - District Court of Colorado - Colorado

Case 1:01-cr-00350-WYD

Document 427

Filed 09/01/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 01-CR-350-WJD UNITED STATES OF AMERICA, Plaintiff, v. JASON PRICE, Defendant. MOTION FOR PERMISSION TO TRAVEL OUT-OF-STATE Jason Price, through counsel, hereby moves this Court for an Order permitting him to travel to the State of Florida on a regular basis, on the following grounds: 1. Mr. Price has been on pretrial release since August, 2001. During this

period he has been supervised by all nine pretrial services officers, has always complied with pretrial services requirements, and has made an excellent adjustment to pretrial release. He has previously sought and been granted several travel requests, all without incident. 2. Homes. Mr. Price is a builder/remodeler working under the name of Price Custom His company has a construction project in Florida. This project requires

frequent travel and not always at predictable times. 3. motion. AUSA Greg Rhodes and USPO Kristine Zorn have no objection to this

Case 1:01-cr-00350-WYD

Document 427

Filed 09/01/2006

Page 2 of 2

WHEREFORE, Mr. Price respectfully requests an Order granting permission to travel to the State of Florida on a regular basis as herein above set forth. Respectfully submitted this 1st day of September, 2006.

/s John M. Richilano John M. Richilano Richilano & Gilligan, P.C. 633 17th Street, Suite 1700 [email protected] Denver, CO 80202 Phone: (303) 893-8000 Fax: (303) 893-8055 CERTIFICATE OF SERVICE I hereby certify that on this 1st day of September 2006, I filed the foregoing MOTION TO TRAVEL with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following email addresses: Gregory Hayze Rhodes Assistant United States Attorney 1225 17th St., Suite 700 Denver, CO 80202 [email protected] Kristine Zorn Pretrial Services 1961 Stout St., Suite 525 Denver, CO 80294 [email protected] /s Donna M. Brummett

-2S:\Price, Jason\Pleadings\2006.09.01 Motion to Traveldoc.doc