Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:00-cr-00239-WDM

Document 89

Filed 05/30/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 00-cr-00239-WDM UNITED STATES OF AMERICA, Plaintiff, v. JUAN ALONSO CALDERON, Defendant. and LBI MECHANICAL, INC., Garnishee.

MOTION TO DISMISS WRIT OF GARNISHMENT

Plaintiff, United States of America, by its undersigned attorneys, moves this Court for an order to dismiss the writ of garnishment filed February 4, 2008, against the above-named Defendant. As grounds therefor, Plaintiff states: 1. Judgment was entered herein on October 20, 2000, in the amount of $79,800.00. 2. A Writ of Garnishment was filed on February 4, 2008 against the Defendant's employer, LBI Mechanical, Inc. 3. The garnishment should be dismissed because defendant resigned his position.

Case 1:00-cr-00239-WDM

Document 89

Filed 05/30/2008

Page 2 of 3

WHEREFORE, Plaintiff respectfully requests that the Court dismiss the Writ of Garnishment filed on February 4, 2008 in the above captioned case. Respectfully submitted, TROY A. EID United States Attorney Dated: May 30, 2008 By: s/ Lisa A. Christian LISA A. CHRISTIAN Assistant U. S. Attorney 1225 17th Street, Suite 700 Denver, CO 80202 303-454-0100 [email protected] Attorneys for Plaintiff United States of America

Case 1:00-cr-00239-WDM

Document 89

Filed 05/30/2008

Page 3 of 3

CERTIFICATE OF MAILING I hereby certify that a true and correct copy of the foregoing MOTION TO DISMISS WRIT OF GARNISHMENT was placed in the United States mail, postage prepaid, on May 30, 2008, addressed to: LBI MECHANICAL, INC. Attn: Jennifer Minarik 1587 Bentley Drive Corona, CA 92879 Juan Alonso Calderon 15640 E. 168th Avenue Brighton, CO 80601

S/ Lisa A. Christian Office of the U.S. Attorney