Free Reply to Response to Motion - District Court of Colorado - Colorado

Case 1:00-cv-01658-JLK

Document 25

Filed 02/03/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action 00 CV 1658 JLK MIGUEL ANGEL TORRES DE LA CRUZ Petitioner, v. JOSEPH GREENE, US-INS, Denver, Colorado. ________________________________________________ RESPONSE TO MOTION TO TRANSFER ________________________________________________ Prior to transferring this case to the Court of Appeals Mr. Torres De La Cruz requests the opportunity to include evidence that he has completed all his obligations under his sentence in Utah. The fact of his successful completion has been disputed by the government and, in part, informed the government's opposition. The government argued Mr. Torres De La Cruz would not be analogously eligible for Federal First Offender Act (FFOA) treatment even if such treatment were applied to his case because he had not completed probation. However, he did successfully complete probation on September 16, 2002. Please see attached. Wherefore, Petitioner respectfully responds 1

Case 1:00-cv-01658-JLK

Document 25

Filed 02/03/2006

Page 2 of 2

this 3 day of February, 2006 /s/Jim Salvator Jim Salvator, #21055 Attorney for Miguel Angel Torres De La Cruz 1643 Erin Way Lafayette, CO 80026 (303) 604-0320

CERTIFICATION OF SERVICE (CM/ECF) I hereby certify that on this 3rd day of February 2006 I electronically filed this pleading with the Clerk of the Court using CM/ECF system which will send notification to the following: [email protected] /s/Jim Salvator Jim Salvator, #21055 Attorney for Miguel Angel Torres De La Cruz 1643 Erin Way Lafayette, CO 80026 (303) 604-0320

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