Free Motion to Expedite - District Court of Colorado - Colorado

Case 1:01-cr-00149-WDM

Document 545

Filed 10/16/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO JUDGE WALKER D. MILLER Criminal Action No. 01-CR-00149-WDM UNITED STATES OF AMERICA, Plaintiff, v. 12. NADIA C. PASILLAS, Defendant.

__________________________________________________________________
DEFENDANT'S MOTION FOR IMMEDIATE SENTENCING

__________________________________________________________________
Come now the Defendant, Nadia C. Pasillas, by and through her attorney of record, John Mosby, and respectfully moves this Honorable Court to immediately sentence Defendant at her change of plea hearing on October 18, 2007. In support thereof, Defendant would state the following: 1. Prior to filing this motion, Defendant's attorney conferred with the AUSA and he

has no objections to this motion. 2. 3. The Defendant is six months pregnant and requires medical care. Defendant will need to be placed in a medical facility by the Bureau of Prisons as

soon as possible since she has been informed by her doctor that travel will become a medical issue in her 7th month of pregnancy. 4. The Probation Office has been contacted and it is anticipated that a probation

report will be available at the hearing.

Wherefore, Defendant moves this Court for an Order granting her motion for immediate

Case 1:01-cr-00149-WDM

Document 545

Filed 10/16/2007

Page 2 of 2

sentencing at the change of plea hearing.

DATED: October 16, 2007

Respectfully submitted, s/ John Mosby John Mosby Attorney for Defendant Pasillas 621 17th Street, Suite 925 Denver, Colorado 80293 303.623.1355

CERTIFICATE OF SERVICE I hereby certify that on this 16th day of October 2007, I electronically filed the foregoing document entitled, DEFENDANT'S MOTION FOR IMMEDIATE SENTENCING with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following via e-mail: AUSA David M. Gaouette

s/ John Mosby John Mosby

2