Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:02-cr-00004-AWT

Document 158

Filed 05/09/2005

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT __________________________________________ ) UNITED STATES OF AMERICA ) ) CRIMINAL NO. v. ) 3:02CR4(AWT) ) LUIS SANTIAGO ) May 5, 2005 __________________________________________)

DEFENDANT'S MOTION FOR EXTENSION OF TIME Defendant Luis Santiago, by his counsel, hereby moves for an extension of time to file his opening brief concerning the remand ordered by the Court of Appeals. Currently, that brief is due May 16, 2005. Defendant requests an extension of time until July 15, 2005, for the following reasons. 1. The undersigned counsel was appointed only recently, on April 28, 2005,

to represent Defendant in this matter. 2. Previously, Defendant has been through sentencing and appeal in this

matter, plus extensive involvement in a parallel proceeding involving allegations against Defendant and a co-defendant, United States v. Ciarcia, all of which must be reviewed by counsel. 3. The sentencing issues raised in this proceeding are, to a great extent,

issues of first impression arising from United States v. Booker, 125 S.Ct. 738 (2005) and United States v. Crosby, No. 03-1675 (2d Cir. Feb. 2, 2005). 4. The Government has no objection to this extension.

Case 3:02-cr-00004-AWT

Document 158

Filed 05/09/2005

Page 2 of 2

WHEREFORE, the Defendant respectfully requests that the Court extend the deadline for Defendant to file his opening brief until July 15, 2005. ______________________________ Charles F. Willson (# ct24129) NEVINS & NEVINS LLP 102 Connecticut Boulevard P. O. Box 280658 East Hartford, CT 06128 Tel: (860) 289-4455 fax: 860-289-8968 email: [email protected]

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was sent by first-class mail, postage prepaid, on May 5, 2005, to Counsel for the United States Raymond F. Miller Assistant U.S. Attorney U.S. Attorney's Office 157 Church Street 23rd Floor New Haven, CT 06510

______________________________ Charles F. Willson