Free Motion to Continue - District Court of Colorado - Colorado


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Date: November 27, 2007
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State: Colorado
Category: District Court of Colorado
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Case 1:00-cr-00484-WDM

Document 50

Filed 11/27/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CASE NO. 00-cr-00484-WDM

UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY JAMES SMEDLEY, Defendant. ________________________________________________________________________ UNOPPOSED MOTION TO CONTINUE DEADLINE FOR SUPERVISED RELEASE HEARING ________________________________________________________________________

The Defendant, Anthony Smedley ("Mr. Smedley"), by and through his courtappointed counsel, Matthew C. Golla ("counsel"), hereby requests this Honorable Court to continue the supervised release hearing, currently set for November 30, 2007, for 45days or to a future date thereafter that is agreeable with the Court's calendar and that of the respective parties. In support of the motion, the defendant would show: 1. The defendant is awaiting a supervised release hearing scheduled for

November 30, 2007 at 9:00am. 2. Undersigned counsel reviewed the violation report today and needs additional

time to review the report with Mr. Smedley. Counsel is also intending to draft a sentencing memorandum regarding a variance pursuant to 18 U.S.C. ยง 3553(a).

Case 1:00-cr-00484-WDM

Document 50

Filed 11/27/2007

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3.

Additionally, Mr. Smedley has requested that counsel investigate the

possibility of Mr. Smedley being paroled on a state sentence before his final revocation hearing. 4. 5. A continuance of 45 days is requested. Counsel contacted Assistant United States Attorney Suneeta Hazra, and she

does not oppose a continuance. Wherefore, the defendant respectfully requests the Court to continue the supervised release hearing for 45 days or to date agreeable with the Court's calendar.

Respectfully submitted, RAYMOND P. MOORE FEDERAL PUBLIC DEFENDER

s/ Matthew C. Golla MATTHEW C. GOLLA Office of the Federal Public Defender 633 17 th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 E-mail: [email protected] Attorney for Defendant

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Case 1:00-cr-00484-WDM

Document 50

Filed 11/27/2007

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CERTIFICATE OF SERVICE I hereby certify that on November 27, 2007, I electronically filed the foregoing UNOPPOSED MOTION TO CONTINUE DEADLINE FOR SUPERVISED RELEASE HEARING with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Brenda Taylor, Assistant United States Attorney [email protected] [email protected] [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: Suneeta Hazra, Assistant United States Attorney (via e-mail) [email protected] James Murphy, United States Probation Officer (via e-mail) [email protected]

Anthony James Smedley (via mail) Reg. No. 30058-013 c/o Jefferson County Jail P.O. Box 16700 Golden, CO 80402-6700

s/ Matthew C. Golla MATTHEW C. GOLLA Attorney for Defendant Office of the Federal Public Defender 633 17 th Street, Suite 1000 Denver, CO 80202 Telephone: (303) 294-7002 FAX: (303) 294-1192 [email protected]

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