Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00185-JCH Document 38 Filed 08/29/2005 Page 1 of 3
I UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : NO. 3:03CR185 (JCH)
VS. :
JAMES DEMPSEY : AUGUST 26, 2005
MOTION FOR ENLARGEMENT
OF TIME RE: SENTENCING .
For the reasons which follow, the defendant moves to enlarge the time period for
sentencing from August 31st, until sometime after October l, 2005:
K 1. On June 30, 2003, the defendant, James Dempsey, pleaded guilty to a
violation of Title 18 U.S.C., Section 371, Conspiracy to Defraud the United States.
2. His sentencing is presently scheduled for August 31st before this Court.
3. The defendant is presently out on bond and has been reporting to Pre-Trial
Services without incident.
4. The defendant had no criminal history.
5. At this point, Mr. Dempsey pre-sentence report is not yet available.
6. U.S.P.O. Mark Myers needs said time to complete his report.
7. The defendant will forthwith submit a waiver of rights he may have under
the Speedy Trial Act.
“ .... .... . ....

Case 3:03-cr-00185-JCH Document 38 Filed 08/29/2005 Page 2 of 3
8. The defendant has been informed by the government (A.U.S.A. William
Nardini) that it does not obj ect to said motion being granted.
WHEREFORE, it is so moved that sentencing in this matter be postponed and
rescheduled forlsome time after October lst.
DEFENDANT, JAMES DEMPSEY
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Richard R. Brown
Brown, Paindiris & Scott, LLP
100 Pearl Street
Hartford, CT 06103
Tel. (860) 522-3343
Fed. Bar No. Ct00009
BROWN PAINDIRIS Sc SCOTT, LLP - ATTORNEYS AT LAW
100 PEARL STREET -· HARTFORD, CONNECTICUT 05103 - (860) 522-3343 - JURIS NO. 20767

Case 3:03-cr-00185-JCH Document 38 Filed 08/29/2005 Page 3 of 3
CERTIFICATION
This is to certify that a copy of this motion was sent postage prepaid this 26th day
of August, 2005 to the following:
A.U.S.A. William Nardini
Office of U.S. Attorney _
P.O. Box 1824
New Haven, CT 06510
U.S.P.O. Mark Myers
Office of U.S. Probation
157 Church Street, 22nd Floor
New Haven, CT 06510
U.S.P.O. Kattya Lopez
Office of U.S. Probation
450 Main Street
Hartford, CT 06103
41;/?< A
Richard R. Brown
BROWN PAINDIRIS E: SCOTT, LLP —- ATTORNEYS AT LAW
100 PEARL STREET - HARTFORD, CONNECTICUT 06103 — (860) 522-3343 —- JURIS NO. 20767