Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00229-RNC

Document 137

Filed 06/30/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. : : No. 3:03CR229(RNC)

FAUSTINO FLEURY : ____________________________________

MOTION FOR EXTENSION OF TIME The United States Attorney, through H. Gordon Hall, Assistant United States Attorney, respectfully moves the Court to continue the date for sentencing in this case from the currently assigned date of July 15, 2005 and the date set for written submissions from the currently assigned date of July 6, 2005 for two weeks, so that submissions would be due on July 20, 2005 and sentencing would be on July 29, 2005. In support of the motion, the undersigned represents as follows: 1. On July 24, 2005, the defendant appeared before the Court for sentencing. 2. Following argument, the Court indicated it desired further information regarding the quantity of heroin properly attributable to the defendant for sentencing purposes, and set the referenced schedule. 3. The undersigned, who is Government counsel in this case, was not present at the proceedings on June 24, as he was on trial before the Honorable Janet C. Hall, U.S.D.J., in an unrelated criminal case. On the afternoon of June 27, the undersigned was advised by AUSA Slater, who was present at the proceedings on June 24, of the Court's concerns and the schedule. The undersigned then contacted counsel for one or more cooperating witnesses, who may be in a position to provide pertinent information at the sentencing hearing, and arranged pre-hearing interviews. The schedule for witness counsel will not permit interviews to take place before July 6, and follow-up

Case 3:03-cr-00229-RNC

Document 137

Filed 06/30/2005

Page 2 of 3

may be necessary, depending on the information provided. 4. The undersigned has been advised that defense counsel may also seek additional time within which to prepare for the hearing scheduled by the Court, and does not object to this motion. WHEREFORE, the Government respectfully requests that the Court grant this motion.

Respectfully Submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

H. GORDON HALL ASSISTANT U.S. ATTORNEY Federal Bar No.ct05153 157 CHURCH STREET NEW HAVEN, CONNECTICUT 06510 (203) 821-3700 SO ORDERED: _______________________________ ROBERT N. CHATIGNY CHIEF UNITED STATES DISTRICT JUDGE Dated at Hartford, Connecticut, this ____ day of June, 2005.

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Case 3:03-cr-00229-RNC

Document 137

Filed 06/30/2005

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing Government's Motion to Continue Sentencing was sent this 29th day of June, 2005, via first class mail, postage pre-paid to

Thomas C. Furniss, Esq. Furniss & Quinn 248 Hudson Street Hartford, CT 06106-1777

___________________________________ H. GORDON HALL ASSISTANT U.S. ATTORNEY

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