Free Motion for Leave to File - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB

Document 1379

Filed 09/24/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Robert E. Blackburn Criminal Action No. 04-cr-00103-REB UNITED STATES OF AMERICA, Plaintiff, v. 5. JANNICE McCLAIN-SCHMIDT, et al., Defendants. ______________________________________________________________________________ MOTION FOR LEAVE TO FILE SENTENCING HEARING MEMORANDUM ______________________________________________________________________________ Defendant, JANNICE McCLAIN SCHMIDT, by her counsel Paula M. Ray, and pursuant to REB Cr. Practice Standard V.D.1., moves this Honorable Court for permission to file a Sentencing Hearing Memorandum in anticipation of the hearing on resentencing of Ms. Schmidt, presently set for Friday, October 19, 2007, at 1:30 p.m. Counsel for defendant believes that the record that was made prior to Ms. Schmidt's previous sentencing should be supplemented with the appropriate case law and defendant's theory of the case on resentencing. This supplemental pleading will better able this Court to determine the issues prior to resentencing.

Case 1:04-cr-00103-REB

Document 1379

Filed 09/24/2007

Page 2 of 2

For this purpose, counsel requests permission to file her sentencing hearing memorandum on or before Monday, October 8, 2007. DATED this 24th day of September, 2007. Respectfully submitted,

s/ Paula M. Ray 1801 Broadway, Suite 1100 Denver, CO 80202-3839 Telephone: 303.292.0110 Email: [email protected]

CERTIFICE OF SERVICE I hereby certify that on this 24th day of September, 2007, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Peter Bornstein, Esq. [email protected] Thomas Hammond, Esq. [email protected] Declan J. O'Donnell, Esq. [email protected] Matthew T. Kirsch, Esq. [email protected] Richard N. Stuckey, Esq. [email protected] Thomas Goodreid, Esq. [email protected] Ronald Gainor, Esq. [email protected]

s/ Paula M. Ray

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