Free Motion to Join - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB

Document 614

Filed 01/04/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Robert E. Blackburn

Case Number: 04-cr-00103-REB

UNITED STATES OF AMERICA, Plaintiff, v.

4. CHARLES FRANKLIN LEWIS, Defendant.

DEFENDANT CHARLES LEWIS' MOTION TO JOIN FILINGS OF CODEFENDANTS NORMAN SCHMIDT AND JANNICE McLAIN SCHMIDT ________________________________________________________________________

Comes now the Defendant, Charles Franklin Lewis, by and through his undersigned counsel, Ronald Gainor, who files this Motion to Join Filings of CoDefendants Norman Schmidt and Jannice McLain Schmidt and, in support would state the following; 1. On December 30, 2005, undersigned counsel filed a Motion to Dismiss Counts 1,7, 8, and 9 of the Second Superseding Indictment on behalf of Charles Lewis. 2. Counsel for Co-Defendants Norman Schmidt and Jannice Mclain Schmidt have also filed motions to dismiss attacking the Second Superseding Indictment. 3. Undersigned counsel now seeks the Court's permission to join in those pleadings.

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Case 1:04-cr-00103-REB

Document 614

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4. Specifically, counsel seeks to join in Jannice McLain Schmidt's Motion to Dismiss Counts 1, 3-9, 16, 17 and 20-29 of Second Superseding Indictment, Norman Schmidt's Supplemental Motion to Dismiss 2nd Superseding Indictment and Norman Schmidt's Motion to Dismiss Second Superseding Indictment (filed on October 24, 2005). 5. The granting of this motion to join will avoid the necessity of duplicate

pleadings and will result in the significant savings of time for the Court and all parties in this litigation. Wherefore, based on the above and foregoing, undersigned counsel for defendant Charles Franklin Lewis, requests that this Honorable Court grant the instant Motion to Join Filings of Co-Defendants Norman Schmidt and Jannice McLain Schmidt.

Dated this 4th day of January, 2006

Respectfully submitted, s/ Ronald Gainor RONALD GAINOR 6414 Fairways Drive Longmont, CO 80503 (303) 448-9646(phone) (303) 447-0930 (Facsimile) [email protected] Attorney for Charles Lewis

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Case 1:04-cr-00103-REB

Document 614

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that I have electronically filed the foregoing Motion to Join Filings of Co-Defendants Norman Schmidt and Jannice McLain Schmidt on this 4th day of January, 2006 with the Clerk of the Court using the ECF system which will send notification of such filing to the following e-mail addresses:

Matthew Kirsch [email protected] Peter Bornstein [email protected] Thomas Hammond [email protected] Thomas Goodreid [email protected] Daniel Smith [email protected] Declan O'Donnell [email protected] Paul Daiker [email protected]

s/ Ronald Gainor

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Case 1:04-cr-00103-REB

Document 614

Filed 01/04/2006

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