Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 2:90-cr—OOO18—AHN Document 224 Filed O3/22/2006 Page1 0f3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
United States of America, :
v. : DOCKET NO: H—90—18 (AHN)
Frank A Pugliano : March 20, 2006
MOTION FOR EXAMINATION OF JUDGMENT
DEBTOR AND FOR A HEARING ON DEFENDANT’S
ABILITY TO PAY THE JUDGMENT
The Government in the above—entitled action represents:
1. That judgment was imposed upon the defendant, Frank A
Pugliano, before the United States District Court, District of
Connecticut, on November 25, 1991. As part of the judgment, the
defendant was ordered to pay restitution in the amount of $50,000.00.
The defendant's last payment was made on 04—AUG—04 in the amount of
$25.00. As of March 20, 2006, total restitution owed by Frank A
Pugliano is $47,922.00.
2. On February 3, 2006, the Government served by mail a set of
Post Judgment Interrogatories and Request for Production on the
defendant, Frank A Pugliano. Although more than 30 days have passed
since the service of said Interrogatories and Request for Production,
the defendant has not filed any response, or requested extension of
time.
Therefore, pursuant to Connecticut Practice Book § 13—20(b)(2),
which provides that in the event of a debtor's failure to answer
interrogatories, a debtor examination "shall be conducted before the
judicial authority", and C.G.S. § 52—351b(c) and F.R.Civ.P.69(a) which
authorize the Government to seek "supplemental discovery orders as may
be necessary to ensure disclosure", and F.R.Civ.P.37(d), which

Case 2:90-cr—OOO18—AHN Document 224 Filed O3/22/2006 Page 2 of 3
authorizes this Court to "make such orders in regard to the failure
[to answer interrogatories] as are just", the federal plaintiff
respectfully requests that an order be entered requiring the defendant
to appear before a Judge or Magistrate Judge of this Court and then
and there be examined under oath concerning his property and means of
paying said judgment.
The federal plaintiff further moves that as part of the aforesaid
order, the defendant be required to produce at the hearing: (1) copies
of defendant's income tax records filed for the last two years; (2)
all other documents sought by government's Request for Production; and
(3) a completed financial statement to assist the Court's evaluation
of the defendant's ability to pay. A proposed Order is attached
hereto for the Court's consideration.
Respectfully Submitted,
KEVIN J. O’CONNOR
UNI ED STATES A EY
( .
A 1, ` dl;
CHRISTIN SCIARRINO
ATTORNE BAR NO: CT03393
ATTORNEY FOR THE DEPARTMENT OF JUSTICE
. UNITED STATES ATTORNEY'S OFFICE
P. O. BOX 1824
NEW HAVEN, CT 06508
TELEPHONE: (203) 821-3700
FAX: (203) 773-5392
E—MAIL: [email protected]

Case 2:90-cr—00018—AHN Document 224 Filed O3/22/2006 Page30f3
CERTIFICATION
This is to certify that a copy of the foregoing was mailed
postage prepaid on this 20th day of March, 2006 to:
Frank A Pugliano
1390 Memorial Avenue
West Springfield, Massachusetts 01089
, ,¢
I 6%/
CHRISTIN SCIARRINO
ASSIST UNITED STATES ATTORNEY