Free Motion to Modify Conditions of Release - District Court of Colorado - Colorado

Case 1:03-cr-00128-WYD

Document 252

Filed 07/12/2007

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case Number: 03-cr-00128-WYD UNITED STATES OF AMERICA, Plaintiff, v. DANA WEST a.k.a "ABRAHAM" Defendant.

MOTION TO MODIFY TERMS OF RELEASE

Defendant, Dana West a.k.a "Abraham", by and through his attorney, Harvey A. Steinberg of the law firm of Springer and Steinberg, P.C., hereby moves the Court for an Order modifying the terms of the Defendant's release. AS GROUNDS THEREFORE, Defendant states as follows: 1. Pursuant to the Court's latest Order, the Defendant has been released but with provisional conditions that were imposed by Judge Watanabe. The Defendant is seeking modification of those terms because he believes they are onerous and unrelated to the purposes of his particular situation. 3. Specifically, the Defendant is requesting that the ankle monitor requirement be lifted. The Defendant does not represent any type of flight risk and in fact, would have no where to go. Further, pursuant to this Court's prior orders the Defendant has deemed not to be dangerous. 4. Additionally, the Defendant is requesting that restriction on meeting with and having a relationships with other pretrial detainees be lifted. 5. The Defendant was extended for an extended period of time and has developed friendships and relationships with other similarly situated individuals. As a result, the Defendant requests that he be allowed to continue those friendships. 6. The Defendant is requesting that the Court grant this modification. 2.

Case 1:03-cr-00128-WYD

Document 252

Filed 07/12/2007

Page 2 of 2

WHEREFORE, Defendant respectfully requests that this motion be granted. DATED this 12th day of July, 2007.

Respectfully submitted, s/Harvey A. Steinberg Harvey A. Steinberg Attorneys for Dana West Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

CERTIFICATE OF SERVICE I hereby certify that on July 12, 2007, I electronically filed the foregoing MOTION TO MODIFY TERMS OF RELEASE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

Jim Hearty [email protected]

s/Brenda Rodriguez For Harvey A. Steinberg Attorneys for Dana West Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

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