Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cr-00274-WDM

Document 47

Filed 05/11/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 04-cr-00274-WDM UNITED STATES OF AMERICA, Plaintiff, v. MICHELLE ABEYTA, Defendant. __________________________________________________________________ UNOPPOSED MOTION TO CONTINUE SUPERVISED RELEASE REVOCATION HEARING __________________________________________________________________ The Defendant, Michelle Abeyta ("Ms. Abeyta"), by and through court appointed counsel, Assistant Federal Public Defender Matthew C. Golla, respectfully requests this Honorable Court to continue the pending supervised release revocation hearing for after August 3, 2007, in the above-captioned case. In support of this motion, undersigned counsel ("counsel") would show: 1. A supervised release revocation hearing originally scheduled for

February 23, 2007 was vacated due to the continued status of a pending case, United States v. Michelle Abeyta, 06-cr-00368-REB.

Case 1:04-cr-00274-WDM

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2.

In a subsequent order, counsel was ordered to schedule Ms. Abeyta's

supervised release matter after March 1, 2007. Counsel, if at all possible, would like to reschedule this matter after August 3, 2007. 3. Ms. Abeyta is scheduled to be sentenced in her other pending matter on

August 3, 2007. Her mending matter, involving conspiracy to possess stolen mail, will constitute a violation of her supervised release before this Court. 3. Bob Brown, the Assistant United States Attorney assigned to this case,

does not oppose this motion. 4. In light of this situation, counsel requests this Honorable Court to set the

above-mentioned supervised release revocation hearing after August 3, 2007 and allow both the government and counsel to contact chambers to reset the hearing. WHEREFORE, counsel requests that this Honorable Court grant this motion.

Respectfully submitted, RAYMOND P. MOORE FEDERAL PUBLIC DEFENDER

s/ Matthew C. Golla MATTHEW C. GOLLA Office of the Federal Public Defender 633 17 th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 E-mail: [email protected] Attorney for Defendant

Case 1:04-cr-00274-WDM

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Filed 05/11/2007

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CERTIFICATE OF SERVICE

I hereby certify that on May 11, 2007, I electronically filed the foregoing UNOPPOSED MOTION TO CONTINUE SUPERVISED RELEASE REVOCATION HEARING with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Phil Brimmer, Assistant United States Attorney [email protected] [email protected] [email protected] [email protected] and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the non-participant's name:

Bob Brown, Assistant United States Attorney (by e-mail) [email protected]

Michelle Abeyta (by mail) Reg. No. 32767-013 c/o Douglas County Jail 4000 Justice Way Castle Rock, CO 80104

s/ Matthew C. Golla MATTHEW C. GOLLA Attorney for Defendant Office of the Federal Public Defender 633 17 th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected]