Free Motion to Continue - District Court of Colorado - Colorado

Case 1:03-cr-00495-WDM

Document 492

Filed 11/20/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Action No. 03-cr-00495-WDM UNITED STATES OF AMERICA, Plaintiff, vs. 2. RODGERICK L. LACKEY, Defendant.

DEFENDANT RODGERICK LACKEY'S UNOPPOSED MOTION TO CONTINUE JURY TRIAL

COMES NOW, the Defendant Roderick Lackey, by and through his CJA appointed counsel, R. Scott Reisch, and hereby moves this Honorable Court to continue the jury trial currently scheduled for January 14, 2008. As grounds, the Defendant states as follows: 1. 2. Mr. Lackey was scheduled for trial on January 14, 2008. It was understood that Mr. Lackey would be tried after Mr. Deberry who

is scheduled for trial on December 3, 2007. 3. Mr. Deberry has moved to continue his trial date which is now scheduled

for February 11, 2008. 4. Undersigned counsel moves for a continuance based upon the ends of

justice as well as the further discovery that has become available so that counsel can adequately and effectively prepare to represent Mr. Lackey at trial. 5. motion. Assistant United States Attorney, David M. Conner, does not object to this

Case 1:03-cr-00495-WDM

Document 492

Filed 11/20/2007

Page 2 of 3

6.

Assistant United States Attorney David M. Conner and undersigned

counsel pre-cleared a trial date of March 17, 2008 for trial. WHEREFORE, Mr. Lackey, through counsel, respectfully moves this Honorable Court to grant this Unopposed Motion to Continue the Jury Trial. Dated this 20th day of November, 2007.

Respectfully submitted,

s/ R. Scott Reisch R. Scott Reisch 12021 Pennsylvania Street, Suite 204 Denver, CO 80241 Telephone: (303) 291-0555 FAX: (720) 904-5797 E-mail: [email protected] [email protected] Attorney for Defendant Rodgerick L. Lackey

Case 1:03-cr-00495-WDM

Document 492

Filed 11/20/2007

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CERTIFICATE OF SERVICE I hereby certify that on November 20, 2007, I electronically filed the foregoing DEFENDANT RODGERICK LACKEY'S UNOPPOSED MOTION TO CONTINUE JURY TRIAL with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

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David M. Conner [email protected] [email protected];[email protected] J. Michael Dowling [email protected] Mark Cameron Johnson MarkJohnson297@ hotmail.com

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And I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner (mail, hand-delivery, etc.) indicated by the nonparticipant's name: Frederick D. Deberry 09303-042 U.S. Penitentiary ­ Max P.O. Box 8500 Florence, CO 81226-8500

s/R. Scott Reisch R. Scott Reisch Attorney for Defendant Rodgerick L. Lackey The Reisch Law Firm, LLC 12021 Pennsylvania Street, Suite 204 Denver, CO 80241 Telephone: (303) 291-0555 FAX: (720) 904-5797 E-mail: [email protected] [email protected]