Free Motion to Continue - District Court of Colorado - Colorado

Case 1:03-cr-00495-WDM

Document 355

Filed 12/20/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 03-cr-00495-WDM-1,2 UNITED STATES OF AMERICA, Plaintiff, v. 1. FREDERICK D. DEBERRY, 2. RODGERICK L. LACKEY, a/k/a Roderick Lackey, Defendants.

GOVERNMENT'S MOTION TO CONTINUE SUPPRESSION HEARING

The United States of America, by and through Joshua Stein, Assistant United States Attorney, hereby moves the Court to continue the suppression hearing set for tomorrow, Thursday, December 21, 2006 at 9:00 a.m. on the following grounds:

The government's witnesses are unable to attend due to the inclement weather which has closed the Denver airport. The government has two essential witnesses, Lt. John Skowronek and C.O. Patrick Griffiths, both residing outside Colorado. Lt. Skowronek's flight from Minneapolis/St. Paul was cancelled today and the soonest available confirmed flight for him would arrive Friday, December 22. C.O. Patrick Griffiths flight from Philadelphia was also cancelled today and

Case 1:03-cr-00495-WDM

Document 355

Filed 12/20/2006

Page 2 of 3

the soonest available confirmed flight for him would arrive tomorrow, December 21, at 3:00 p.m. WHEREFORE, the government moves the Court to continue the suppression hearing and direct all parties to contact the Court's chambers to reschedule the hearing.

Respectfully submitted, TROY A. EID United States Attorney

By: s/ Joshua Gramling Stein JOSHUA GRAMLING STEIN Assistant United States Attorney U.S. Attorney's Office 1225 17th St., Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 Email: [email protected] Attorney for the United States

Case 1:03-cr-00495-WDM

Document 355

Filed 12/20/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 20th day of December, 2006, I electronically filed the foregoing GOVERNMENT'S MOTION TO CONTINUE SUPPRESSION HEARING with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addressed:
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David M. Conner [email protected],[email protected],[email protected] v Mark Cameron Johnson [email protected] Michael J. Norton [email protected],[email protected],[email protected] Randy S. Reisch [email protected],[email protected] Joshua Gramling Stein [email protected],[email protected],[email protected],Ca [email protected],[email protected]

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 non-participant's name: None s/ Joshua Gramling Stein JOSHUA GRAMLING STEIN Assistant United States Attorney U.S. Attorney's Office 1225 17th St., Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 Email: [email protected] Attorney for the United States