Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00188-CFD

Document 120

Filed 02/02/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA vs. MICHAEL SPERO

: 3:03CR188 (CFD) : FEBRUARY 1, 2006 :

MOTION FOR CONTINUANCE OF SENTENCING HEARING Defendant, Michael Spero, by and through his attorney, hereby moves this Honorable Court to continue the sentencing hearing set for February 10, 2006 for the reasons set forth below: (1) The motion for admission pro hac vice of Cheryl J. Sturm was granted on January 27, 2006. (2) New counsel has been in the process of collecting the record that pertains to resentencing. She has not had the opportunity to review the complete file or to meet with Mr. Spero in preparation for sentencing. (3) The undersigned has consulted John A. Danaher, AUSA and Mr. Danaher does not oppose the request to continue the sentencing hearing. (4) The undersigned, Richard S. Cramer, Attorney at Law and John A. Danaher, AUSA respectfully propose the dates of March 8, 9, 10, 14, 15, 16, 17, 2006 as possible dates for the continuance. WHEREFORE, Defendant moves this Honorable Court to continue the sentencing date from February 10, 2006 to a date convenient to the Court and the parties.

Case 3:03-cr-00188-CFD

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Filed 02/02/2006

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Dated: February 1, 2006

Respectfully submitted, /s/Cheryl J. Sturm Cheryl J. Sturm Attorney at Law 387 Ring Road Chadds Ford, Pa. 19317 484-771-2000 [email protected] Federal Bar No. CT12801

Case 3:03-cr-00188-CFD

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CERTIFICATE OF SERVICE Cheryl J. Sturm, Attorney at Law, hereby certifies that on the 1st day of February, 2006 she caused a copy of the within Motion for Continuance of Sentencing Hearing to be served upon opposing counsel and all interest parties by United States Mail, first class postage pre-paid and addressed as follows: Richard S. Cramer Attorney at Law 449 Silas Deane Highway Wethersfield, CT 06109 John A. Danaher, III Assistant U.S. Attorney 450 Main Street Hartford, CT 06103

/s/Cheryl J. Sturm Cheryl J. Sturm Attorney at Law

Case 3:03-cr-00188-CFD

Document 120

Filed 02/02/2006

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