Free Motion for Miscellaneous Motion regarding Reduction of Sentence re Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH

Document 1939

Filed 08/29/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. KEVIN HAMLETTE : : : NO. 3:00CR263 (JCH) AUGUST 27, 2008

MOTION TO EXTEND TIME The defendant, Kevin Hamlette, through the undersigned attorney, hereby respectfully requests an extension of time to show cause why his petition to reduce his guidelines pursuant to 18 U.S.C. §3582(c)(2) and 994(u), as well as Amendment 706 to the Sentencing Guidelines, should be granted. The undersigned is yet to have any contact with Mr. Hamlette, who is incarcerated at FCI Williamsburg in South Carolina, to gather information that could be applicable resentencing under 18 U.S.C §3553(a). Efforts are being made to have telephone contact, but so far this has not been successful. Defendant's case is unusual in light of the crack amendment guidelines and that he was sentenced as a career offender and the sentencing court did not depart downward. Additional legal research will be necessary in order to file a motion in support of the relief sought by the defendant. Defendant respectfully requests that he have until September 15, 2008, to show cause why the relief sought should be granted. The undersigned also notes that by motion dated April 28, 2008, the defendant

Case 3:00-cr-00263-JCH

Document 1939

Filed 08/29/2008

Page 2 of 2

requested appointment of counsel other than the undersigned because defendant had previously filed "a 2255 motion against Attorney Cramer..." The government does not object to the granting of this request. DEFENDANT, KEVIN HAMLETTE

By:________________________________ Richard S. Cramer 250 Hudson Street Hartford, CT 06106 Tel. (860) 560-7704 Federal Bar No. ct00016 Email: [email protected] CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing was mailed postage prepaid this 27th day of August 2008 to: Stephen Reynolds Assistant U. S. Attorney 157 Church Street New Haven, CT 06510

_________________________________ Richard S. Cramer