Free Motion for Hearing - District Court of Colorado - Colorado

Case 1:00-cr-00201-WYD

Document 69

Filed 08/06/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CRIMINAL CASE NO.: 00-cr-00201-W YD UNITED STATES OF AMERICA, Plaintiff, v. 1. CHRISTOPHER E. CARLYLE, Defendant.

UNOPPOSED REQUEST FOR COURT TO SET HEARING ON VIOLATION OF SUPERVISED RELEASE

The defendant, Christopher E. Carlyle, by and through undersigned counsel, hereby requests this Court set a hearing on the supervised release violation pending in this case. As grounds, defendant states: 1. The defendant appeared before this Court on June 5, 2008, for a

hearing on violations of supervised release. The Court continued the hearing indefinitely in order for U.S. Probation to contact R.S.A. to discuss the possibility of Defendant reentering their program. Additionally, Mr. Carlyle had a pending state court matter in Garfield County which needed to be concluded. 2. In further conversations with USPO Patrick Lynch, it appears that

neither RSA nor CareNet (two federal providers of sex offender treatment) will accept the Defendant into their programs. Additionally, on July 24, 2008, Mr.

Case 1:00-cr-00201-WYD

Document 69

Filed 08/06/2008

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Carlyle was sentenced to 18 months Colorado Department of Corrections after conviction on sex assault of a child (the date of offense was May 1, 1998). 3. Mr. Carlyle has been returned to federal custody and is currently

housed at the Jefferson County Jail. W HEREFORE, all parties to this case would request this Court set a hearing as soon as possible to address the pending violation of supervised release. Respectfully submitted, RAYMOND P. MOORE Federal Public Defender

s/ Janine Yunker JANINE YUNKER Assistant Federal Public Defender 633 Seventeenth Street, Suite 1000 Denver, Colorado 80202 Telephone: (303) 294-7002 Facsimile: (303) 294-1192 [email protected] Attorney for Defendant

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Case 1:00-cr-00201-WYD

Document 69

Filed 08/06/2008

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CERTIFICATE OF SERVICE I hereby certify that on August 5, 2008, I electronically filed the foregoing UNOPPOSED REQUEST FOR COURT TO SET HEARING ON VIOLATION OF SUPERVISED RELEASE 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 U.S. Attorney [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 non-participant's name: Patrick Lynch (Via e-mail) U.S. Probation [email protected]

s/ Janine Yunker JANINE YUNKER Assistant Federal Public Defender 633 Seventeenth Street, Suite 1000 Denver, Colorado 80202 Telephone: (303) 294-7002 Facsimile: (303) 294-1192 [email protected] Attorney for Defendant

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