Case 3:02-cr-00313-AWT
Document 56
Filed 08/25/2006
Page 1 of 2
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. RAYMOND ORTIZ : : : CRIMINAL NO. 3:02CR313(AWT) : : AUGUST 25, 2006
GOVERNMENT'S MOTION FOR EXTENSION OF TIME, NUNC PRO TUNC On June 12, 2006, the Court granted defendant Raymond Ortiz' Motion for Extension of Time to File Response to Endorsement Order, until August 1, 2006. Counsel for the Government requests an extension of time of two weeks, until September 5, 2006, to respond to defendant's Motion for Resentencing pursuant to United States v. Crosby. In support of this request, the undersigned avers that his three-week absence from this District, from July 28, 2006 until August 17, 2006, combined with the press of business, necessitates this request for an extension of time. This motion is the first filed by the Government seeking an extension of time to respond. Defense counsel, Bethany Phillips, Esq., has been contacted and has not objection to this request. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY
BY:
JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY Federal Bar No. CT05101 THOMAS V. DAILY ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct05101 450 Main Street Hartford, CT 06103 (860) 947-1101
For:
Case 3:02-cr-00313-AWT
Document 56
Filed 08/25/2006
Page 2 of 2
CERTIFICATE OF SERVICE I hereby certify that the foregoing was mailed this 25th day of August, 2006, to the following: Bethany Lynne Phillips, Esq. Advocates Law Firm 11 Franklin Square New Britain, CT 06051-2604
By:
__________________________ JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY
FOR: THOMAS V. DAILY ASSISTANT UNITED STATES ATTORNEY
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