Free Motion for Bond - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB-MEH

Document 642

Filed 01/31/2006

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 04-cr-00103 (RB) UNITED STATES OF AMERICA, Plaintiff, v. 6. MICHAEL SMITH, Defendant.

MOTION TO PERMIT DEFENDANT MICHAEL D. SMITH TO PARTICIPATE IN THE STATUS HEARING ON FEBRUARY 3, 2006, VIA TELEPHONE COMES NOW, the Defendant (6) Michael Smith, by and through Counsel and for Motion To Permit Defendant to Participate in the Status Hearing on February 3, 2006, via Telephone, states: 1. The Status Conference in the captioned case is scheduled for Friday, February 3, 2006 at 1:30 p.m. 2. That Defendant, Michael D. Smith, requests this Court's permission to attend the Conference via telephone due to lack of sufficient funds to cover the cost of transportation to attend this scheduled hearing, as well as prior business commitments. 3. 4. That Defendant resides in Spokane, Washington. Defendant's funds have been depleted primarily because of attorney's fees to contend with a civil suit by the Attorney General's Office in Spokane, Washington, including a $10,000 payment this month to settle it, (largely from borrowed funds). WHEREFORE, the Defendant, Michael D. Smith, by and through undersigned counsel, Declan J. O'Donnell, Esq. respectfully moves this Honorable Court to permit Defendant to participate in the Status Hearing which is scheduled for February 3, 2006 at 1:30 p.m., via telephone for the reasons stated above.
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Case 1:04-cr-00103-REB-MEH

Document 642

Filed 01/31/2006

Page 2 of 4

Respectfully Submitted, DECLAN JOSEPH O'DONNELL, P.C.

/s/ Declan J. O'Donnell Declan J. O'Donnell, #4412 Attorney for Defendant Smith 499 S. Larkspur Dr. Castle Rock, CO 80104 Phone (303) 688-1193 Facsimile (303) 663-8595 Email: [email protected]

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Case 1:04-cr-00103-REB-MEH

Document 642

Filed 01/31/2006

Page 3 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

United States of America, Case No. 04-CR-103 (RB) Plaintiff, vs. 6. Michael Smith, Defendant Certificate of Service (CM/ECF)

I hereby certify that on January 31, 2006, a true and correct copy of this foregoing Motion to Permit

Defendant Smith to Participate via Telephone in the Status Hearing Scheduled for February 3, 2006
was electronically filed with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants via first class mail, postage pre-paid to the following recipients:

/s/ Declan J. O'Donnell Declan J. O'Donnell, #4412 Attorney for Defendant Smith 499 S. Larkspur Dr. Castle Rock, CO 80104 Phone (303) 688-1193 Facsimile (303) 663-8595 Email: [email protected] Matthew T. Kirsch, Esq. Assistant U.S. Attorney 1225 17th St. Ste. 700 Denver, CO 80202 Ronald Gainor, Esq. Attorney for Charles Lewis 6414 Fairways Drive Longmont, CO 80503 Peter R. Bornstein, Esq. Attorney for Norman Schmidt 1600 Broadway, Ste. 2350 Denver, CO 80202

Thomas E. Goodreid, Esq. Attorney for George Weed 1801 Broadway, Ste. 1100 Denver, CO 80202 Paul B. Daiker, Esq. Attorney for George Beros Zukerman, Daiker & Lear Co., LPA 2000 East Ninth Street, Ste. 700 Cleveland, OH 44115

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Case 1:04-cr-00103-REB-MEH

Document 642

Filed 01/31/2006

Page 4 of 4

Daniel Smith, Esq. Attorney for Janice McClain Schmidt 1900 Grant Street, Ste. 580 Denver, CO 80203 Thomas J. Hammond, Esq. Thomas J. Hammond, PC Attorney for Norman Schmidt 1544 Race Street Denver, CO 80206 Mr. Robert P. Sticht Law Offices of Robert P. Sticht PO Box 49457 Las Angeles, CA 90049 Mr. Michael D. Smith Via Electronic Mail

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