Free Motion to Travel - District Court of Colorado - Colorado

Case 1:04-cr-00048-WYD

Document 112

Filed 05/11/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case Number 04-cr-00048-WYD UNITED STATES OF AMERICA, Plaintiff, v. DAN LEHMAN, Defendant. _________________________________________________________________________________ MOTION TO TRAVEL OUT OF STATE _________________________________________________________________________________ The Defendant, Dan Lehman, by and through his attorney, Harvey A. Steinberg, of the law firm of Springer and Steinberg, P.C., hereby requests permission to travel out of state. AS GROUNDS THEREFORE, the Defendant states as follows: 1. 2. June 15, 2006. 3. Undersigned counsel's office left a message with the Assistant United States The Defendant is requesting permission to travel to Vernal, Utah for his job. The Defendant would leave the state of Colorado on May 15, 2006, and return on

Attorney, Mark Barrett regarding his position. As of the filing of this motion, his position is unknown. 4. Undersigned counsel's office spoke to Sarah Hoppe, the Defendant's Pretrial

Supervisor, regarding her position. Ms. Hoppe indicated she does not have an objection. Further, the Defendant would be checking-in with Ms. Hoppe during the period he is out of the jurisdiction. 5. This matter is currently scheduled for Sentencing on July 13, 2006.

DATED THIS 11TH DAY OF MAY, 2006.

Case 1:04-cr-00048-WYD

Document 112

Filed 05/11/2006

Page 2 of 2

Respectfully submitted, s/Harvey A. Steinberg Attorney for Dan Lehman Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

CERTIFICATE OF SERVICE I hereby certify that on May 11, 2006, I electronically filed the foregoing MOTION TO TRAVEL OUT OF STATE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Mark Barrett Email: [email protected]

I hereby certify that on May 11, 2006, I faxed the foregoing MOTION TO TRAVEL OUT OF STATE to: Sarah Hoppe United States Pretrial Fax: 303-844-5439 s/Brenda Cruz For Harvey A. Steinberg Attorney for Dan Lehman Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

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