Free Reply/Response Misc - District Court of Connecticut - Connecticut

Case 3:03-cr-00188-CFD

Document 135

Filed 07/14/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES v. MICHAEL G. SPERO : : : CRIMINAL NO. 3:03CR188(CFD) JULY 14, 2006

GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION TO WITHDRAW AS COUNSEL

On July 13, 2006, counsel for the defendant moved to be relieved as counsel in the abovecaptioned matter. The defendant is currently scheduled to be resentenced on July 26, 2006 at 2:30 p.m. The defendant's current counsel is the third attorney who has represented him in this matter, a matter that did not involve a trial and that has been marked by delays, postponements, and recalcitrance by the defendant on those occasions when he has been in the courtroom. The Government requests that, at a minimum, the instant motion not be resolved on the papers, but rather by oral argument, either through the use of video conference equipment at the Court's convenience, or else in person on July 26, 2006, at the time currently set aside for sentencing. The history of this case suggests that it is necessary for there to be a specific plan going forward, or else there will be additional, protracted delays in resolving this matter. The Government takes this position, not to inconvenience defense counsel or to prejudice the defendant in any way, but rather for the purpose of attempting to bring closure to the victim and his family, all of whom have been adversely affected,

Case 3:03-cr-00188-CFD

Document 135

Filed 07/14/2006

Page 2 of 2

not only by the conduct that led to this prosecution, but by the fact that this matter seems virtually incapable of final resolution.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct05101 450 Main Street, Rm. 328 Hartford, CT 06103 (860) 947-1101

CERTIFICATION OF SERVICE I hereby certify that a copy of the foregoing has been mailed this 14th day of July, 2006, to the following: Cheryl J. Sturm, Esq. 387 Ring Road Chadds Ford, PA 19317 Richard S. Cramer, Esq. 449 Silas Deane Highway Wethersfield, CT 06109-2120

_________________________________________ JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY

2