Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB

Document 644

Filed 01/31/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Robert E. Blackburn

Case Number: 04-cr-00103-REB

UNITED STATES OF AMERICA, Plaintiff, v.

4. CHARLES FRANKLIN LEWIS, Defendant.

DEFENDANT CHARLES LEWIS' UNOPPOSED MOTION TO APPEAR BY TELEPHONE AT FEBRUARY 3, 2006 STATUS CONFERENCE HEARING ________________________________________________________________________

Comes now the Defendant, Charles Franklin Lewis, by and through his undersigned counsel, Ronald Gainor, who files this Unopposed Motion to Appear By Telephone At February 3, 2006 Conference Hearing in support would state the following; 1. This case is currently set for a Status Hearing on February 3, 2006 at 1:30

P.M. before this Honorable Court. 2. Undersigned counsel is currently out of the District of Colorado preparing for

and expecting to start a 2 day jury trial in Fort Lauderdale, Florida on Wednesday, February 1, 2006 in the matter of State of Florida v. Randy Lee Truman, Case Number 04-401729-CF-10A.

-1-

Case 1:04-cr-00103-REB

Document 644

Filed 01/31/2006

Page 2 of 3

3. Although counsel expects to complete the trial in time to return to Colorado on Thursday night, unforeseen circumstances may develop in that case (i.e extended jury deliberations) which might prevent counsel from flying home and attending the Status Hearing in Mr. Lewis' case in person. 4. Based on these circumstances, counsel requests permission to attend the

February 3, 2006 Status Hearing by telephone. 5 Assistant U.S Attorney Matthew Kirsch has no objection to the relief requested

in this motion Wherefore, based on the above and foregoing, undersigned counsel for defendant Charles Franklin Lewis, requests that this Honorable Court grant the instant Unopposed Motion and allow to him to appear by telephone at the February 3, 2006 Status Conference Hearing.

Dated this 31st day of January, 2006

Respectfully submitted, s/ Ronald Gainor RONALD GAINOR 6414 Fairways Drive Longmont, CO 80503 (303) 448-9646(phone) (303) 447-0930 (Facsimile) [email protected] Attorney for Charles Lewis

-2-

Case 1:04-cr-00103-REB

Document 644

Filed 01/31/2006

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that I have electronically filed the foregoing Motion to Appear By Telephone At February 3, 2006 Status Conference Hearing on this 31th day of January, 2006 with the Clerk of the Court using the ECF system which will send notification of such filing to the following e-mail addresses:

Matthew Kirsch [email protected] Peter Bornstein [email protected] Thomas Hammond [email protected] Thomas Goodreid [email protected] Daniel Smith [email protected] Declan O'Donnell [email protected] Paul Daiker [email protected]

s/ Ronald Gainor

-3-