Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:00-cr-00226-SRU

Document 88

Filed 03/08/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ) ) ) ) ) ) ) ) )

UNITED STATES OF AMERICA, v. MARVIN SPAN Defendant.

Docket No. 3:00-cr-00226-SRU March 6, 2006

MOTION TO LATE FILE CROSBY MEMORANDUM Defendant Marvin Span, by and through undersigned counsel, respectfully moves the Court for leave to late file the attached memoranda (redacted and under seal) in support of Crosby remand resentencing. By Order of the Court, Docket #86, simultaneous briefing was due on March 3. However, undersigned counsel did not receive a legible version of information relevant to the Court's considerations until March 4. Counsel for the government was apprised of this fact by voice message on Friday afternoon and, as of this writing, has expressed no objection. Respectfully submitted,

BY:

/s/ Todd Bussert TODD A. BUSSERT, CT24328 103 Whitney Avenue, Suite 4 New Haven, CT 06510-1229 (203) 495-9790; Fax: (203) 495-9795 [email protected] Appointed Counsel (CJA) for Marvin Span

Case 3:00-cr-00226-SRU

Document 88

Filed 03/08/2006

Page 2 of 2

CERTIFICATE OF SERVICE I, Todd Bussert, hereby certify that a copy of the foregoing was served via first class mail, postage prepaid, this 6th day of March 2006 on the following: Alex Hernandez, Supervisory AUSA United States Attorney's Office 915 Lafayette Boulevard Bridgeport, CT 06604

/s/ Todd Bussert Todd Bussert