Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cr-00386-EWN

Document 40

Filed 07/17/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

CASE NO. 04-cr-00386-EWN UNITED STATES OF AMERICA, Plaintiff, v. SHAR HANULCIKOVA PADGETT, Defendant. _____________________________________________________________________________ MOTION TO RESET VIOLATION HEARING _____________________________________________________________________________ Comes now the Defendant, Shar Hanulcikova Padgett, by and through her attorney, Assistant Federal Public Defender Edward R. Harris, and moves to reset the August 11 violation hearing in this case for the reasons set forth below: 1. By Minute Order dated July 10, 2006, this Court vacated the July 21, 2006

probation violation hearing and reset that hearing to August 11, 2006. Counsel received no ECF notice of that Minute Order, but on July 17, 2006, learned from his client that the hearing had been reset. 2. refundable. Counsel will be out of town on August 10 and 11, 2006. His tickets are non-

Case 1:04-cr-00386-EWN

Document 40

Filed 07/17/2006

Page 2 of 3

WHEREFORE, Defendant respectfully requests that this matter be reset to a date at which counsel can be present. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Edward R. Harris Edward R. Harris Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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Case 1:04-cr-00386-EWN

Document 40

Filed 07/17/2006

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that on July 17, 2006, I electronically filed the foregoing MOTION TO RESET VIOLATION HEARING with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected]

s/ Edward R. Harris Edward R. Harris Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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