Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

· “ Case 2:90-cr-00018-AHN Document 211 Filed 11/23/2005 Page 1 of 3 g
UNITED STATES DISTRICT COURT a Fg-1; gi,
_ DISTRICT OF CONNECTICUT g` .--4I .. ii.: ,
NUI} 23 A ll= ifi
UNITED STATES OF AMERICA ) ZIIIIS
) Cr. No. H-90·flg§m$Tr{IrgT I
vs. ) Civ. No. 3:95C\/?i‘1iIj?¢I5’l“»¢ilFII*&ls]4 r
)
GAETANO MILANO ) `
UNITED STATES OF AMERICA ) .
) Cr. No. H-90-18 -
vs. ) Civ. No. 3:95CV1171 [AHN]
)
· LOUIS PUGLIANO ) ,
UNITED STATES OF AMERICA ) =
) Cr. No. I-I-90-18 ‘
vs. ) Civ. No. 3:95CV133O [AHN] .
) .
FRANK A. PUGLIANO ) g

PETITIONER LOUIS PUGLIANO’S OPPOSITION TO
GOVERNMENTS MOTION FOR EXTENSION OF TIME I
Petitioner Louis Pugliano opposes the Governments motion for a nunc pro func
I
extension of time to respond to Petitioners’ renewed motion for discovery. Under Local
Rule 7(a) the Government’s response to Petitioners’ motion, Hled September 21, 2005,
was due on or before October 12, 2005. The Governments first acknowledgment of
the motion was made 35 days later and does not assert that the efforts to prepare a
response were even begun within the 21 days provided in Local Rule 7(a) for the filing
I 2


e k Case 2:90-cr-00018-AHN Document 211 _ Filed 11/23/2005 Page 2 of 3
of oppositions. Under Rule 7(b)(1)(b) an extension of 30 days was available tothe
Government for the asking, but no such request was made. The Government’s motion
states that this is its first request for an extension and that it seeks only 30 days; in fact l
it seeks an extension of 65 days. in the May 3, 2005 hearing in Vincent Ferrara v. ‘
United States, United States District Court, District of Massachusetts No. CA OO-11693 E
the Government pressed hard for permission to make a presentation arguing that the T
Grasso murder constituted "relevant conduct" for Ferrara, who was to be resentenced
because the Government had coerced him into pleading guilty to a murder he did not
commit, in order to avoid being convicted of that murder on Government-sponsored
false testimony. The transcript of the May 3, 2005 proceeding before Judge Wolf is
attached to Petitioner Milano’s discovery motion as Exhibit B. See p. 33-36, 62-63,
Mercurio's role in the Grasso case was part and parcel of that issue in that hearing. Id;
64 [AUSA Herbertz: "Mercurio would have been liable as weIl."]. Accordingly, Petitioner
Pugliano suggests that the Government’s request is unreasonable.
WHEREFORE, Petitioner renews his request that the Court order the
Government to answer Petitioners' discovery requests on or before December 16, T
2005.

1, * Case 2:90-cr-00018-AHN Document 211 Filed 11/23/2005 Page 3 of 3
LOUIS PUGLIANO, PETITIONER 1
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1 . Thompson .
1 pson & Thompson, P.C. é
1‘ - Main Street, Suite 320
Springfield, NIA 01103
[413] 739-2100
Federal Bar # CT15144 j
Certificate of Service
I hereby certify that a true and accurate copy of the foregoing document was
served upon counsel for all parties by first class mail, postage prepaid, addressed to i
each at his most recent address listed in the court’s docket, this 21S‘ day of November,
2005. §
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F n M. Thompson ,
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