Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cr-00443-WYD

Document 35

Filed 12/06/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-CR-443-D UNITED STATES OF AMERICA, Plaintiff, v. CHRISTOPHER KETCHUM, Defendant. ______________________________________________________________________ ________ UNOPPOSED MOTION TO CONTINUE SENTENCING HEARING AND DEADLINES RELEVANT TO THE SENTENCING HEARING

Defendant, Christopher Ketchum moves this court to continue the sentencing currently scheduled for December 21, 2005 and to set new deadlines for filing objections to the pre-sentence report and filing motions for downward departure consistent with the new sentencing date. As grounds for this motion, Mr. Ketchum states: 1. 2. The court previously rescheduled this matter at the request of counsel Unfortunately, undersigned counsel will be out of the country on

December 21, 2005. 3. Counsel has tentatively cleared a date and time of January 31, 2006 at

11:00 with chambers.

Case 1:04-cr-00443-WYD

Document 35

Filed 12/06/2005

Page 2 of 2

4.

Counsel has spoken with AUSA Conner who agrees that additional time Mr. Conner has no objection to this requested

would be useful to both parties.

continuance and is available on January 31, 2006 at 11:00 a.m. Counsel has also spoken with Ms. Valentin of the probation department who indicated no objection to the continuance as well as her availability on January 31, 2006 at 11:00a.m. Respectfully submitted, s/ Mitchell Baker __________________________ Mitchell Baker Walter Gerash Attorneys for Defendant Ketchum 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 6th day of December, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail address:

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David M. Conner [email protected] [email protected];[email protected] Walter L. Gerash [email protected] [email protected] Lonn M. Heymann [email protected] [email protected] s/ Mitchell Baker _______________________________