Motion for Writ of Habeas Corpus ad Prosequendum by USA as to Chandler Simbeck — USA v. Foreman (Dkt. 66, D. Colo.)

Record facts

U.S. District Court for the District of Colorado · No. 1:21-cr-00165-WJM · Doc. 66 · 2022-08-12 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
 
Criminal Action No. 21-cr-00165-RM 
 
 
UNITED STATES OF AMERICA, 
 
 
Plaintiff, 
 
v. 
 
2. CHANDLER SIMBECK, 
 
 
Defendant. 
                                                                                                                                                                  
 
MOTION FOR WRIT OF HABEAS CORPUS AD PROSEQUENDUM 
                                                                                                                                                              
 
 
The United States of America, by and through the United States Attorney for the 
District of Colorado, petitions the Court for Writ of Habeas Corpus Ad Prosequendum and 
states as follows: 
 
1.     The Defendant, Chandler Simbeck, DOB: 07/26/1992, Jail ID: P00002274, 
Inmate number: B2203336, is now confined in the Larimer County Jail.   
 
2.     A hearing in the above-captioned case will be held forthwith in the United 
States District Court for the District of Colorado before a United States Magistrate Judge, 
and it is necessary that he be present in person during the proceedings, appearances, 
and final disposition of this case.  
 
WHEREFORE your Petitioner moves the Court to order that a Writ of Habeas 
Corpus Ad Prosequendum be issued by this Court to the United States Marshal for the 
District of Colorado, or any other United States Marshal, or to any other federal law 
enforcement officer, requiring said federal law enforcement officer to serve the writ on the 
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Warden, Superintendent, or Custodian of any place or institution where the Defendant is 
confined, and requiring said federal law enforcement officer to produce the Defendant 
before a United States Magistrate Judge for the said defendant’s initial appearance; and 
to hold the said defendant at all times in custody as an agent of the United States of 
America; and that immediately after the conclusion of the proceedings and final 
disposition of the above-entitled case in the United States District Court for the District of 
Colorado, shall return the said defendant to the institution where he was confined, under 
safe and secure conduct. 
 
 
Respectfully submitted this 12th day of August, 2022. 
 
 
 
 
 
 
 
 
COLE FINEGAN 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
By: 
s/Robert Brown                                            
 
 
 
 
 
Robert Brown 
Assistant United States Attorney 
 
 
 
 
 
United States Attorney's Office 
 
 
 
 
 
1801 California Street, Suite 1600 
 
 
 
 
 
Denver, Colorado 80202 
 
 
 
 
 
Telephone: (303) 454-0100 
 
 
 
 
 
Email: Robert.Brown5@usdoj.gov 
 
 
 
 
 
Attorney for the Government 
 
 
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CERTIFICATE OF SERVICE 
 
I certify that on this 12th day of August, 2022, I electronically filed the foregoing 
MOTION FOR WRIT OF HABEAS CORPUS AD PROSEQUENDUM with the Clerk of 
the Court using the CM/ECF system which will send notification of such filing to all 
counsel of record in this case. 
 
 
 
 
By:  s/Elaina Wohr                           
        Legal Assistant 
        United States Attorney=s Office 
 
 
 
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