Free Motion for Decrease for Acceptance of Responsibility - District Court of Colorado - Colorado

Case 1:04-cr-00444-EWN

Document 63

Filed 05/11/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00444-EWN-1 UNITED STATES OF AMERICA, Plaintiff, v. 1. JEREMY JAY BARGER, Defendant.

GOVERNMENT'S MOTION FOR DECREASE IN DEFENDANT'S OFFENSE LEVEL FOR ACCEPTANCE OF RESPONSIBILITY PURSUANT TO U.S.S.G. § 3E1.1(b)

The United States of America, by Troy A. Eid, United States Attorney, and Philip A. Brimmer, Assistant United States Attorney, moves the Court to decrease the defendant's offense level by one additional level pursuant to United States Sentencing Guideline § 3E1.1(b) and in support states: The defendant assisted the government in the prosecution of his own misconduct by timely notifying the government of his intention to enter a plea of guilty, thereby permitting the government to avoid preparing for trial and permitting the government and the Court to allocate their resources efficiently. WHEREFORE, the government respectfully moves the Court to decrease the defendant's offense level by one additional level pursuant to United States Sentencing Guideline § 3E1.1(b).

Case 1:04-cr-00444-EWN

Document 63

Filed 05/11/2007

Page 2 of 3

Respectfully submitted, TROY A. EID United States Attorney

by: s/ Philip A. Brimmer PHILIP A. BRIMMER Assistant United States Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 FAX: (303) 454-0403 E-mail: [email protected] Attorney for Government

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Case 1:04-cr-00444-EWN

Document 63

Filed 05/11/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 11th day of May, 2007, I electronically filed the foregoing GOVERNMENT'S MOTION FOR DECREASE IN DEFENDANT'S OFFENSE LEVEL FOR ACCEPTANCE OF RESPONSIBILITY PURSUANT TO U.S.S.G. § 3E1.1(b) and proposed ORDER with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail address(es): Virginia Grady [email protected] and I hereby certify that I have emailed the foregoing to the non CM/ECF participant: Kurt Thoene U.S. Probation [email protected]

s/ Janet D. Zinser JANET D. ZINSER Supervisory Legal Assistant U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone: 303-454-0327 Fax: 303-454-0403 E-mail address: [email protected]

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