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

Case 1:04-cr-00443-WYD

Document 38

Filed 01/31/2006

Page 1 of 3

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00443-WYD-1 UNITED STATES OF AMERICA, Plaintiff, v. 1. CHRISTOPHER KETCHUM, Defendant.

GOVERNMENT'S MOTION FOR DECREASE IN DEFENDANT'S OFFENSE LEVEL FOR ACCEPTANCE OF RESPONSIBILITY PURSUANT TO U.S.S.G. § 3E1.1(b)

COMES NOW, the United States of America, by William J. Leone, United States Attorney, and David M. Conner, Assistant United States Attorney, and moves the Court to decrease the defendant's offense level by one additional level pursuant to United States Sentencing Guideline § 3E1.1(b) and in support states: The defendant assisted the government in the prosecution of his own misconduct by timely notifying the government of his intention to enter a plea of guilty, thereby permitting the government to avoid preparing for trial and permitting the government and the Court to allocate their resources efficiently.

Case 1:04-cr-00443-WYD

Document 38

Filed 01/31/2006

Page 2 of 3

WHEREFORE, the government respectfully moves the Court to decrease the defendant's offense level by one additional level pursuant to United States Sentencing Guideline § 3E1.1(b).

Respectfully submitted, WILLIAM J. LEONE United States Attorney

By: s/ David M. Conner DAVID M. CONNER Assistant U.S. Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 E-mail: [email protected] Attorney for the Government

Case 1:04-cr-00443-WYD

Document 38

Filed 01/31/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 31st day of January, 2006, I electronically filed the foregoing GOVERNMENT'S MOTION FOR DECREASE IN DEFENDANT'S OFFENSE LEVEL FOR ACCEPTANCE OF RESPONSIBILITY PURSUANT TO U.S.S.G. § 3E1.1(b) AND PROPOSED ORDER with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

Walter Gerash, Esq. [email protected] Mitchell Baker, Esq. [email protected] Emily Valentin U.S. Probation Office [email protected]

s/ Janet D. Zinser JANET D. ZINSER Supervisory Legal Assistant U.S. Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0332 Fax: (303) 454-0403 [email protected]