Free Motion to Travel - District Court of Colorado - Colorado

Case 1:04-cr-00048-WYD

Document 107

Filed 03/14/2006

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. _________________________________________________________________________________ UNOPPOSED 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. The Defendant is requesting permission to travel to Townsend, Washington. The Defendant would leave the state of Colorado on March 17, 2006, and return on

March 24, 2006. 3. Undersigned counsel's office left a message with the Assistant United States

Attorney, Mark Barrett regarding his position. Mr. Barrett left a message with this office and stated that he does not object to this motion being granted as long as pretrial does not object. 4. Undersigned counsel's office left a message with Sarah Hoppe, the Defendant's

Pretrial Supervisor regarding her position. Ms. Hoppe left a message with this office and stated that she does not object to this motion being granted. 5. This matter is currently scheduled for Sentencing on May 11, 2006.

DATED THIS 14TH DAY OF MARCH, 2006.

Case 1:04-cr-00048-WYD

Document 107

Filed 03/14/2006

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 March 14, 2006, I electronically filed the foregoing UNOPPOSED 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 March 14, 2006, I faxed the foregoing UNOPPOSED MOTION TO TRAVEL OUT OF STATE to: Sarah Hoppe United States Pretrial Fax: 303-844-5439 s/Jan Cooley 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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