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