Notice Adopting Prior Motion to Exclude 180 Days from Speedy Trial by Chandler Simbeck — USA v. Foreman (Dkt. 97, D. Colo.)

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
 
Criminal Case No. 21-cr-00165-RM 
 
UNITED STATES OF AMERICA 
 
Plaintiff, 
 
v. 
 
2. CHANDLER SIMBECK, 
 
 
Defendant. 
 
 
NOTICE ADOPTING PRIOR MOTION TO EXCLUDE 180 DAYS FROM THE 
REQUIREMENTS OF THE SPEEDY TRIAL ACT [Doc. 32] 
 
 
 
COMES NOW, Defendant Chandler Simbeck, through counsel, and submits this 
Notice  Adopting Prior Motion to Exclude 180 Days From the Requirements of the Speedy 
Trial Act [Doc. 32].  
Procedural History and Ends-of-Justice-Continuance Expiration Date 
 
Speedy trial in Mr. Simbeck’s case was set to run on January 31, 2022. [Doc. 18.] 
On December 7, 2021, Mr. Simbeck’s previous attorney, Luis Castaneda filed an 
Unopposed Motion to exclude 180 days from speedy trial calculation. [Doc. 32.] That 
same day, a pretrial release warrant was issued for for Simbeck, and speedy was tolled. 
[Doc. 36.] At that point in time, 55 days remained on speedy. On December 13, 2021, the 

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Court granted Mr. Castaneda’s motion. [Doc. 38.] The 70-day clock, exclusive of tolled 
time, was extended from January 28, 2022 to July 27, 2022. Id.  Since the warrant was 
issued, the next time Mr. Simbeck appeared in front of Judge Moore was on September 
29, 2022, which untolled speedy. [Doc. 93.]  
 
Defendant Simbeck submits this notice to the Court endorsing and adopting the 
prior ends-of-justice request made by Mr. Castaneda. Accordingly, Mr. Simbeck’s ends of 
justice continuance should expire on May 22, 2023.  
 
Respectfully submitted this October 13, 2022. 
TYRONE GLOVER LAW, LLC 
 
s/ Tyrone Glover  
 
Tyrone Glover #41529 
TYRONE GLOVER LAW, LLC 
2590 Walnut Street 
Denver, CO 80205 
tyrone@tyroneglover.com 
Phone: 303-577-1655 
 
 
 

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CERTIFICATE OF SERVICE 
 
 
I hereby certify that on October 13, 2022 a true and correct copy of the foregoing 
NOTICE ADOPTING PRIOR MOTION TO EXCLUDE 180 DAYS FROM THE 
REQUIREMENTS OF THE SPEEDY TRIAL ACT was served via ECF/Pacer to the 
parties of record. 
 
 
 
 
 
 
 
TYRONE GLOVER LAW, LLC 
 
 
 
 
 
 
 
 
 
 
 
 
s/ Tyrone Glover 
 
 
 
 
 
 
_________________________ 
 
 
 
 
 
 
Tyrone Glover

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