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

Case 1:04-cr-00379-WYD

Document 64

Filed 12/16/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00379-WYD-1 UNITED STATES OF AMERICA, Plaintiff, v. 1. MICHAEL MENSEN, a/k/a TICK, Defendant.

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

The United States of America, by William J. Leone, United States Attorney, and Philip A. Brimmer, Assistant United States Attorney, 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. 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).

Case 1:04-cr-00379-WYD

Document 64

Filed 12/16/2005

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Respectfully submitted, WILLIAM J. LEONE United States Attorney

by: s/ Philip A. Brimmer PHILIP A. BRIMMER Assistant United States Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 FAX: (303) 454-0403 E-mail: [email protected] Attorney for Government

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Case 1:04-cr-00379-WYD

Document 64

Filed 12/16/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 16th day of December 2005, 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 the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Harvey Abe Steinberg [email protected] [email protected] Alaurice Marie Tafoya-Modi [email protected]

s/ Susan Shapiro SUSAN SHAPIRO Legal Assistant to Philip A. Brimmer U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone: 303-454-0100 Fax: 303-454-0403 E-mail address: [email protected]

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