Free Reply - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB

Document 1035

Filed 03/01/2007

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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 LEWIS' POSITION ON GOVERNMENT'S PROPOSED JURY INSTRUCTIONS AND VERDICT FORM ________________________________________________________________________

Comes now the Defendant, Charles Franklin Lewis, through his undersigned counsel, Ronald Gainor, who files this, his Position on Government's Proposed Jury Instructions and Verdict Form and, in support, would allege the following: 1. Defendant Lewis would move to adopt George Alan Weed's Position on

Government's Proposed Jury instructions as set out in Document # 1032, filed on March 1, 2007. 2. Defendant Lewis would further stipulate to the Government's proposed verdict form

for use in the above-captioned matter. 3. Defendant Lewis respectfully requests the right to supplement the record with any

additional instructions, at the close of the evidence, if necessary.

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Case 1:04-cr-00103-REB

Document 1035

Filed 03/01/2007

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Wherefore, based on the above and foregoing, undersigned counsel for the Defendant, Charles Franklin Lewis, respectfully requests that this Honorable Court allow him to adopt the position of co-counsel in the above-captioned matter. Dated this 1st day of March, 2007

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 1035

Filed 03/01/2007

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CERTIFICATE OF SERVICE (CM/ECF)

I hereby certify that I have electronically filed the foregoing on this 1st day of March, 2007 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] Wyatt B. Angelo [email protected] Peter Bornstein [email protected] Thomas Hammond [email protected] Thomas Goodreid [email protected] Daniel Smith [email protected] Declan O'Donnell [email protected] Mitchell Baker [email protected]

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Case 1:04-cr-00103-REB

Document 1035

Filed 03/01/2007

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Richard Kornfeld [email protected] Richard Stuckey [email protected]

s/ Ronald Gainor

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