Free Motion to Modify Conditions of Release - District Court of Colorado - Colorado

Case 1:04-cr-00433-WDM

Document 470

Filed 02/14/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00433-WDM UNITED STATES OF AMERICA, Plaintiff, V. 5. RAFAEL SAENZ ORTIZ ________________________________________________________________________ UNOPPOSED MOTION TO MODIFY TERMS OF PRE-TRIAL RELEASE BY ALLOWING AN UNSECURED BOND ________________________________________________________________________ Defendant Rafael Saenz Ortiz moves this court to modify the terms of his pre-trial release by no longer requiring that his bond be secured. As grounds for this motion, Mr. Saenz Ortiz states: 1. 2. 3. Mr. Saenz Ortiz was granted bail in this case on October 19, 2004. The bond has been secured by real property. The owners of the property securing the bond wish to refinance the

property. Refinancing cannot be accomplished while the property is being used as security on the bond. 4. The parties have reached a tentative disposition of this case which

would result in Mr. Saenz Ortiz being allowed to plead guilty to a substantially less serious charge than the charge that was the basis of the original bond.

Case 1:04-cr-00433-WDM

Document 470

Filed 02/14/2006

Page 2 of 3

5.

Counsel has discussed this matter with AUSA Greg Holloway and

Sarah Hoppe of who advised counsel that they had no objection to the requested modification. Respectfully submitted, s/ Mitchell Baker __________________________ Mitchell Baker Attorney for Defendant Saenz Ortiz 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 [email protected] CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of February, 2006, 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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Mitchell Baker [email protected] [email protected] Richard James Banta [email protected] [email protected];[email protected] Darren Randal Cantor [email protected] Martha Horwitz Eskesen [email protected] Matthew Rodney Giacomini [email protected] [email protected];[email protected] Gregory Allen Holloway [email protected] [email protected];[email protected] Michael Paul Litman [email protected] Robert S. McCormick [email protected] [email protected] Lisa Anne Polansky [email protected]

Case 1:04-cr-00433-WDM

Document 470

Filed 02/14/2006

Page 3 of 3

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Daniel Joseph Sears [email protected] Harvey Abe Steinberg [email protected] [email protected] Barrett Thomas Weisz [email protected] [email protected]

S/Mitchell Baker __________________________ Mitchell Baker Attorney for Defendant Saenz Ortiz 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 [email protected]