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HomeMy WebLinkAbout2019-cv-901 - Surat v. City of Fort Collins, et al. - 035A - Exhibit A To MotionCOUNTY COURT, LARIMER COUNTY, COLORADO Larimer County Courthouse 201 Laporte Avenue, Suite 100 Ft. Collins, CO 80521 σ COURT USE ONLY σ Plaintiff: The People of the State of Colorado vs. Defendant: MICHAELLA LYNN SURAT David A. Lane, #16422 Killmer, Lane & Newman, LLP 1543 Champa St., Suite 400 Denver, CO 80202 303-571-1000 dlane@kln-law.com Case No: 2017M000965 NOTICE OF APPEAL AND DESIGNATION OF RECORD COMES NOW, Defendant, Michaella Surat, by and through the undersigned attorney hereby gives notice of the intent to appeal the verdict in the above referenced case. STATEMENT OF FACTS 1. A jury trial was held on August 20-24, 2018. Defendant was found guilty. 2. A sentencing proceeding was held on October 22, 2018. 3. Defendant was sentenced to 12 months of probation; 48 hours of community service, to complete a making better choices class within 10 months and complete an ALC evaluation, and comply with treatment plan. NOTICE OF ISSUES ON APPEAL 4. Defendant’s expert was not allowed to testify to rebut the Prosecution’s expert witness. DESIGNATION OF RECORD 5. The County Court’s complete file including all filed motions and exhibits. DATE FILED: January 18, 2019 2:22 PM FILING ID: E3F3864A9B2EA CASE NUMBER: 2017M965 EXHIBIT A Case 1:19-cv-00901-WJM-NRN Document 35-1 Filed 07/24/19 USDC Colorado Page 1 of 2 6. The transcript of the jury trial held on August 20-24, 2018, including defendant’s proposed jury instructions, and any marked exhibits. 7. The transcript from the sentencing proceeding on October 22, 2018. Respectfully submitted this 18th day of January, 2019. s/ David A. Lane David A. Lane #16422 1543 Champa Street, Suite 400 Denver, CO 80202 303-571-1000 dlane@kln-law.com Attorney for Defendant Certificate of Service I certify that on January 18, 2019, I served the foregoing document by filing it with the Court which will generate notice to all counsel of record. Case 1:19-cv-00901-WJM-NRN Document 35-1 Filed 07/24/19 USDC Colorado Page 2 of 2