Free Motion for Miscellaneous Motion regarding Reduction of Sentence re Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH

Document 1915

Filed 06/19/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ------------------------------------------------------x : UNITED STATES OF AMERICA : : v. : : PATRICE ST. SURIN : : ------------------------------------------------------x

Case No. 3:00CR00263(JCH)

June 19, 2008

MOTION FOR EXTENSION OF TIME The defendant, Patrice St. Surin, hereby requests an extension of time within which to respond to the Court's Order To Show Cause. [Doc. 1889] Undersigned counsel has recently determined that prior CJA counsel will not be appearing on behalf of Mr. St. Surin in connection with his matter; accordingly, the Office of the Federal Defender will act on his behalf if he so desires. Counsel now requires an extension of time to contact Mr. St. Surin, obtain his consent to represent him in this matter, research the case, and file an appropriate response to the Court's order. Accordingly, undersigned counsel seeks an extension to and including August 8, 2008, to respond to the Court's Order To Show Cause. This is the defendant's first motion for an extension of this deadline. Counsel notes that in light of Mr. St. Surin's current projected release date of July 2015, it is extremely unlikely that any reduction in his sentence would result in release in 2008 or 2009; thus, this extension of time will not prejudice Mr. St. Surin.

Case 3:00-cr-00263-JCH

Document 1915

Filed 06/19/2008

Page 2 of 2

Respectfully submitted, The Defendant, Patrice St. Surin Thomas G. Dennis Federal Defender

Dated: June 19, 2008

__________/s/______________________ Sarah A. L. Merriam Assistant Federal Defender 265 Church Street, Suite 702 New Haven, CT 06510 Bar No. ct25379 Phone: 203-498-4200 Fax: 203-498-4207 Email: [email protected] CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on June 19, 2008, a copy of the foregoing motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /s/ Sarah A. L. Merriam