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

Case 1:04-cr-00066-EWN

Document 47

Filed 04/28/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 1:04-cr-00066-EWN-01 UNITED STATES OF AMERICA, Plaintiff, v. 1. KEVIN MICHAEL SHANAHAN, Defendant.

GOVERNMENT'S MOTION REGARDING ACCEPTANCE OF RESPONSIBILITY

The United States of America, by and through John W. Suthers, United States Attorney and David M. Conner, Assistant United States Attorney for the District of Colorado, moves this Court pursuant to United States Sentencing Guideline §3E1.1(b) that the Defendant receive the additional 1 level for acceptance of responsibility. As grounds therefore states: The Defendant has assisted authorities in the investigation or prosecution of his own misconduct by timely notifying authorities 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.

Case 1:04-cr-00066-EWN

Document 47

Filed 04/28/2006

Page 2 of 3

WHEREFORE, the United States would respectfully request the Defendant receive a full 3 levels for acceptance of responsibility pursuant to §3E1.1.

Respectfully submitted, WILLIAM J. LEONE United States Attorney

By: s/David M. Conner DAVID M. CONNER Assistant U.S. Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 E-mail: [email protected] Attorney for the Government

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Case 1:04-cr-00066-EWN

Document 47

Filed 04/28/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 28th day of April, 2006, I electronically filed the foregoing GOVERNMENT'S MOTION REGARDING ACCEPTANCE OF RESPONSIBILITY with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Warren Richard Williamson [email protected] [email protected]

and I hereby certify that I have mailed or served the document or paper to the following non CM/ECF participants in the manner (mail, hand deliver, etc.) indicated by the nonparticipant's name:

s/Barbara Gardalen BARBARA GARDALEN Legal Assistant to David M. Conner U.S. Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0403 [email protected]