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GAETANO J. MILANO ) MASTER DOCKET NO.
) 2:90CR18(AHN)
)
v. )
)
UNITED STATES OF AMERICA ) SEPTEMBER S, 2008
)
GAETANO J. MILANO’S MOTION
TO AMEND HIS MOTION UNDER 28 U.S.C. §2255
Gaetano J. Milano hereby moves to amend his motion under 28 U.S.C. §2255 to Vacate,
Set Aside, or Correct Sentence. In support of this motion, Mr. Milano states the following:
l. Through predecessor counsel, Mr. Milano first filed a motion pursuant to
28 U.S.C. §2255 to Vacate, Set Aside, or Correct his sentence on June 16, 1995.
2. In July, 1998, the petitioner amended his §2255 motion.
3. The litigation surrounding Mr. Milano’s §2255 motion has been extensive and
vigorously contested.
4. Through the efforts of Magistrate Judge Holly B. Fitzsimmons, the parties have
reached a negotiated resolution through which the parties will ask the Court to grant Mr.
Milano’s Amended Motion under §2255 and re—sentence Mr. Milano.
Case 2:90-cr-00018-AHN Document 272 Filed O9/05/2008 Page 2 of 3
5. In connection with the negotiated resolution before Magistrate Fitzsimmons, the
parties have agreed that the re-sentencing will be based on ineffective assistance of counsel and
that Milano will waive other claims that he has asserted heretofore.
6. The amended §2255 motion that the parties have agreed should form the basis for re-
sentencing is filed herewith.
7. The Government consents to this motion to amend.
PLAINTIFF, GAETANO J. MILANO
Craig aabe
[email protected]
Federal Bar No. ct 04116
Romwson & Coma LLP
280 Trumbull Street
Hartford, CT 06103
Telephone: (860) 275-8200
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Case 2:90-cr-00018-AHN Document 272 Filed O9/05/2008 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was mailed, via iirst—class mail, postage
prepaid, on this 5th day of September, 2008, to the following counsel of record:
Peter S. Jongbloed, Esq.
United States Attorneys Office
157 Church Street, 23rd Floor
New Haven, CT 06508
Ray Lopez
Senior Probation Officer
United States Probation Office
915 Lafayette Blvd
Bridgeport, CT 06604
Craig A. Raabe
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