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

Case 3:00-cr-00227-SRU

Document 1451

Filed 02/10/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ------------------------------------------------- : : UNITED STATES OF AMERICA : No. 3:00 CR 227 (SRU) : v. : : RICARDO ROSARIO, : February 10, 2006 : ------------------------------------------------- : DEFENDANT RICARDO ROSARIO'S MOTION FOR ENLARGEMENT OF TIME TO FILE BRIEF ADDRESSING APPELLATE REMAND Defendant RICARDO ROSARIO, by and through his undersigned CJA counsel, respectfully requests that this court enlarge, by 30 days, to March 8, 2006, the time to file his brief addressing the Appellate Remand in this matter. In support of said motion, undersigned counsel makes the following representations: 1. Defendant Rosario was sentenced following the trial of him and

approximately seven other defendants in the extensive prosecution of the Estrada organization. The prosecution produced significant materials which were relied upon in the sentencing of Defendant Rosario. Undersigned counsel is making every effort to review the extensive record to determine what matter should properly be brought to the court's attention for its consideration in light of the new cases which have prompted the remand. 2. For this reason Defendant Rosario, through his CJA counsel, respectfully

requests that the court enlarge, to March 8, 2006, the deadline for submitting his brief.

ORAL ARGUMENT NOT REQUESTED
LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9

Case 3:00-cr-00227-SRU

Document 1451

Filed 02/10/2006

Page 2 of 3

Defendant Rosario also respectfully requests this motion be granted nunc pro tunc to Monday, February 6, 2006. On that date counsel's office drafted this motion and

contacted the government seeking its position on this request. For reasons having to do with undersigned counsel's complex schedule the motion was, inadvertently, not finalized until this date. 3. AUSA Alex Hernandez has advised undersigned counsel that the

government does not object to the court's granting of this request. 4. Defendant Rosario respectfully requests, therefore, that the court extend

to March 8, 2006, the date to file his brief addressing the appellate remand. 5. brief. This is defendant's second request for an enlargement of time to file said

Respectfully submitted, DEFENDANT RICARDO ROSARIO

By________________________________________ Robert J. Sullivan, Jr. LAW OFFICES OF ROBERT SULLIVAN 190 Main Street Westport, Connecticut 06880 Tel. No. 203/227-1404 Federal Bar No. CT08969

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LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9

Case 3:00-cr-00227-SRU

Document 1451

Filed 02/10/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy hereof was mailed on February 10, 2006 to the following: Alex Hernandez, AUSA Office of U.S. Attorney 915 Lafayette Blvd. Bridgeport, CT 06604

__________________________________ Robert J. Sullivan, Jr.

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LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9