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

Case 1:00-cr-00239-WDM

Document 78

Filed 04/30/2007

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 COOL SUNSHINE HEATING & AIR CONDITIONING, 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 28, 2007, 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 (Special Assessment - $100.00; Restitution - $79,700.00). 2. A Writ of Garnishment was filed on February 28, 2007 against the Defendant's employer, Cool Sunshine Heating & Air Conditioning. 3. The garnishment should be dismissed because defendant has agreed to and signed a voluntary wage agreement.

Case 1:00-cr-00239-WDM

Document 78

Filed 04/30/2007

Page 2 of 3

WHEREFORE, Plaintiff requests that the Court dismiss the Writ of Garnishment filed on February 28, 2007 in the above captioned case. Respectfully submitted, TROY A. EID United States Attorney Dated: April 30, 2007 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 78

Filed 04/30/2007

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 April 30, 2007, addressed to: Cool Sunshine Heating & Air Conditioning Attn: Joy 8380 Welby Road Denver, CO 80229 Juan Alonso Calderon 15640 E. 168th Avenue Brighton, CO 80601

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