Free Motion to Continue - District Court of Colorado - Colorado

Case 1:00-cr-00363-WYD

Document 40

Filed 07/31/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 00-cr-00363-WYD UNITED STATES OF AMERICA, Plaintiff, v. DEVON GLOVER, Defendant. _____________________________________________________________________ UNOPPOSED MOTION TO CONTINUE REVOCATION HEARING _____________________________________________________________________ COMES NOW the defendant, Devon Glover, by and through his undersigned counsel, Virginia L. Grady, and moves to continue the hearing on the petition to revoke supervised release, and as ground, states as follows: 1. 2. The hearing is currently scheduled for August 27, 2007 at 1:30 pm. Following the scheduling of his hearing, counsel received notice of a

sentencing hearing in 03-cr-00232-RPM, a complex and protracted case. That sentencing will be held on Friday, August 24, 2007. 3. Ordinarily, the revocation report is disclosed a few days before the

hearing. Mr. Glover is housed in Georgetown at the Clear Creek County jail. Due to preparations for the sentencing hearing on August 24, as well as other unchangeable commitments, counsel will not be able to travel to Georgetown to review the report for Mr. Glover in time for an August 27 hearing. 4. Counsel has consulted with AUSA Matthew Kirsch and USPO Gary Kruck

about this request. Neither object to a continuance of the hearing.

Case 1:00-cr-00363-WYD

Document 40

Filed 07/31/2007

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5.

If this motion is granted, counsel requests an opportunity to jointly contact

chambers with USPO Kruck to reschedule the hearing. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Virginia L. Grady Virginia L. Grady Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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Case 1:00-cr-00363-WYD

Document 40

Filed 07/31/2007

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CERTIFICATE OF SERVICE

I hereby certify that on July 31 2007, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Matthew Kirsch, USPO [email protected]

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the nonparticipant's name: Gary Kruck, USPO email: [email protected] Devon Glover Reg. No. 29850-013 c/o Federal Detention Center 9595 W. Quincy Ave. Littleton, CO 80123 (via email)

(via U.S. Mail)

s/ Virginia L. Grady Virginia L. Grady Assistant Federal Public Defender 633 17th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected] Attorney for Defendant

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