Free Motion to Revoke - District Court of Colorado - Colorado

Case 1:00-cr-00226-WDM

Document 46

Filed 02/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 00-cr-00226-WDM-1 UNITED STATES OF AMERICA, Plaintiff, v. CHARLES JOHNSON, Defendant.

MOTION TO REVOKE BOND AND SUPERVISED RELEASE

Comes now, the United States of America, by and through the undersigned Assistant United States Attorney, and moves this Honorable Court to revoke the bond of, and issue an arrest warrant for, the above named defendant, and at the conclusion of an appropriate hearing, revoke his supervised release, as follows: 1. Pending the final disposition of his supervised release violation hearing, on January 12, 2007, the defendant was released on his own recognizance. Johnson was still obligated to abide by the supervised release terms imposed by this Honorable Court. 2. On January 14, 2007, the defendant provide a urine sample to Correctional Management Incorporated which tested positive for marijuana. 3. On January 16, 2006, the defendant failed to report to, and on January 19, failed to contact, his supervising probation officer, Gary W. Phillips, as directed by Senior U.S. Probation Officer Phillips.

Case 1:00-cr-00226-WDM

Document 46

Filed 02/07/2007

Page 2 of 3

4. On January 24, 2007, the defendant was arrested by officers from the Aurora Police Department for Felony Possession of a firearm and Possession of drugs (a "brick" of marijuana). The defendant "bonded out" from these state charges and is once again at large. 5. Based on the foregoing the United States, and with the concurrence of Senior U.S. Probation Officer Phillips, asks that the court authorize the issuance of a warrant for the arrest of Charles Johnson for bond condition violations and that the defendant be detained until the conclusion of his final revocation hearing. Respectfully submitted, TROY A. EID United States Attorney BY: s/ Mark J. Barrett MARK J. BARRETT Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0401 E-mail: [email protected] Attorney for Government

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Case 1:00-cr-00226-WDM

Document 46

Filed 02/07/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 7th day of February, 2007, I electronically filed the foregoing MOTION TO REVOKE BOND AND SUPERVISED RELEASE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Janine Yunker Email: [email protected] Gary Phillips U.S. Probation Email: [email protected]

s/ Cathy Palma CATHY PALMA Legal Assistant United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0401 E-mail: [email protected]

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