IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLORADO 

Criminal Action No. 11-cr-0355-MSK 

UNITED STATE OF AMERICA, 

 Plaintiff, 

v. 

2. JOHN PHILLIP GALLEGOS, 

 Defendant. 

______________________________________________________________________________ 

MOTION TO PERMIT CO-COUNSEL TO APPEAR AT MOTIONS HEARING SET 

FOR OCTOBER 14, 2011 IN PLACE OF COUNSEL, WILLIAM TAYLOR 

______________________________________________________________________________ 

 John Phillip Gallegos, by counsel William L. Taylor and Darlene A. Bagley of Ridley, 

McGreevy & Winocur, P.C., hereby moves for an order permitting Darlene A. Bagley to appear 

at the motions hearing set for 4:00 p.m. on October 14, 2011 on behalf of Mr. Gallegos, and to 

permit counsel William L. Taylor not to appear at the hearing, and as grounds therefor states as 

follows: 

1. Mr. Taylor was appointed to represent Mr. Gallegos on September 27, 2011. Doc. 30. 

At the time, Mr. Taylor had a pre-existing scheduling conflict, namely a hearing scheduled in a 

felony witness retaliation case in the District Court of Gunnison County, People v. James 

Maxfield, case number 2011CR0048, at 1:30 p.m. on October 14, 2011. 

2. Co-counsel, Darlene A. Bagley, an experienced criminal defense lawyer in the same firm 

as Mr. Taylor, and a member of the CJA Panel for the District of Colorado in good standing, has 

Case No. 1:11-cr-00355-MSK Document 38 filed 10/14/11 USDC Colorado pg 1 of 3
been working on the matter, has met with Mr. Gallegos, is equally well-versed in the matter as 

Mr. Taylor, and is available to appear this afternoon at the scheduled hearing. 

3. Mr. Gallegos has no objection to Ms. Bagley appearing on his behalf, without Mr. 

Taylor, for purposes of today’s hearing. 

Mr. Gallegos and undersigned counsel, Mr. Taylor, respectfully requests that Mr. Taylor be 

excused from this afternoon’s hearing, and that Ms. Bagley be permitted to appear in substitution 

for Mr. Taylor for the purposes of this hearing. 

Dated October 14, 2011. 

Respectfully submitted. 

 /s/ William L. Taylor

William L. Taylor, #21098 

/s/ Darlene A. Bagley 

Darlene A. Bagley, #35728 

RIDLEY, MCGREEVY & WINOCUR P.C.

303 16th Street, Suite 200 

Denver, CO 80202 

Telephone: (303) 629-9700 

Fax: (303) 629-9702 

E-Mail: wltaylorpc@gmail.com; 

taylor@ridleylaw.com; 

bagley@ridleylaw.com

Attorneys for John Phillip Gallegos 

Case No. 1:11-cr-00355-MSK Document 38 filed 10/14/11 USDC Colorado pg 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on this 14th day of October, 2011, I served a true and correct copy of 

the foregoing MOTION TO PERMIT CO-COUNSEL TO APPEAR AT MOTIONS 

HEARING SET FOR OCTOBER 14, 2011 IN PLACE OF COUNSEL, WILLIAM 

TAYLOR via CM/ECF filing to all parties listed therein including: 

Linda Kaufman 

Assistant United States Attorney 

United States Attorney’s Office 

1225 Seventeenth Street, Suite 700 

Denver, Colorado 80202 

Telephone: (303) 454-0100 

FAX: (303) 454-0401 

E-mail: Linda.Kaufman@usdoj.gov

Attorney for Government 

Edward A. Pluss 

Assistant Federal Public Defender 

633 17th Street, Suite 1000 

Denver, CO 80202 

Telephone: (303) 294-7002 

FAX: (303) 294-1192 

Edward_Pluss@fd.org 

Attorney for Defendant 

Paula M. Ray 

Paula M. Ray, P.C. 

P.O. Box 12554 

Denver, CO 80212-0554 

Telephone: 303-874-5170 

Email: paulamray@earthlink.net

 /s/ Suzy M. Kamps 

 Suzy M. Kamps

Case No. 1:11-cr-00355-MSK Document 38 filed 10/14/11 USDC Colorado pg 3 of 3