Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cr-00403-LTB

Document 721

Filed 05/03/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Action Number:

04 - cr - 00403 - LTB

UNITED STATES OF AMERICA, Plaintiff, v. 17.) RENEE ALVAREZ, Defendant.

AMENDED UNOPPOSED MOTION TO CONTINUE CHANGE OF PLEA HEARING

COMES NOW Defendant Renee Alvarez by and through his undersigned counsel, Robert J ustin Driscoll of Driscoll Law Office, and moves this Honorable Court for an Order continuing the Change of Plea Hearing which is presently scheduled for Thursday, May 4, 2006 at the hour of 10:00 a.m. In furtherance and support of this motion the Defendant would show unto the Court the following: 1. The Change of Plea Hearing in this matter is currently scheduled for

Thursday, May 4, 2006 at the hour of 10:00 a.m. 2. Counsel for the Defendant has contacted Assistant United States Attorney

Stephanie Podalak and Ms. Podalak does not oppose this motion. 3. A settled disposition in a conflicting J Trial has collapsed and counsel is ury

now going forward with a jury trial before J udge Hoppin in J efferson County Court.

Case 1:04-cr-00403-LTB

Document 721

Filed 05/03/2006

Page 2 of 2

4.

Undersigned counsel is presently scheduled for J Trial in J ury efferson

County Court, before the Honorable Charles T. Hoppin in People v. Mondragon, Case Number 05 M 3000 to commence at 8:00 a.m. on Thursday, May 4, 2006. Due to this scheduling conflict undersigned counsel will be unable to appear for the Change of Plea Hearing in the above captioned matter. 5. No party will be prejudiced by the requested continuance.

Respectfully submitted this 3rd day of May, 2006. D RISCO LL LAW O FFICE Duly signed original on file at Driscoll Law Office /s Robert Driscoll Robert J ustin Driscoll #5729 455 Sherman Street, Suite 310 Denver, CO 80203-4404 (303) 534 - 3233 Attorney for Renee Alvarez Certificate of Service I hereby certify that on this 3rd day of May 2006, a true and correct copy of the forgoing was filed and served via ECF. Duly signed original on file at Driscoll Law Office /s Sarah Culver