Free Waiver of Sentencing Time - District Court of Connecticut - Connecticut

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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : NO. 3:03CR185 (JCH)
VS. :
JAMES DEMPSEY : JANUARY 3, 2005
MOTION FOR ENLARGEMENT
OF TIME RE: SENTENCING
For the reasons which follow, the defendant 1noves to enlarge the Lime period for
sentencing from January 14th, until some time after the scheduled sentencing of Kurt
Claywell, No. 3:03CRlO3(JCH), or sometime in April 2005, which ever is sooner:
l. 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 January 14th 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. The defendant is cooperating with governmental officials as it relates to
other pending cases including that of defendant Kurt Claywell, who has pleaded guilty to
several counts.

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6. At this point the government is unclear if it will need the testimony of Mr.
Dempsey at Mr. Claywell’s sentencing. Consequently, the government, along with the
defendant, Dempsey desires his sentencing to occur after that of Mr. Claywell.
7. The defendant will forthwith submit a waiver of rights he may have under
the Speedy Trial Act.
8. The defendant has been informed by the government (A.U.S.A. William
Nardini) that it does not object to said motion being granted.
WHEREFORE, it is so moved that sentencing in this matter be postponed and
rescheduled for some time after the date assigned for the sentencing of Kurt Claywell.
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 Gu SCOTT. LLP —- ATTORNEYS AT LAW
100 PEARL STREET — HARTFORD. CONNECTICUT 06103 — (860) 522-3343 - JURIS NO. 20767

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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : NO. 3:03CR185 (JCH)
VS. :
JAMES DEMPSEY : JANUARY 3, 2005
WAIVER OF SPEEDY SENTENCING
I hereby waive my rights under the Speedy Trial Ac; 18 U_SYC_ §3 161, g gg;
and request that the time for sentencing be extenfried through April, 2005.
<·-~ »·~ l·ea· »~· g»it»t r.t C rtuls
ames Dempsey____/
BROWN PAINDIRIS Ex SCOTT, LLP — ATTORNEYS AT LAW
100 PEARL STREET - HARTFORD, CONNECTICUT 06103 — (860) 5Z2·3343 - JURIS NO. 20767

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CERTIFICATION
This is to certify that a copy of this motion was sent postage prepaid this 3rd
day of January, 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
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Richard R. Brown
BROWN PAINDIRIS S: SCOTT, LLP — ATTORNEYS AT LAW
100 PEARL STREET - HARTFORD, CONNECTICUT 06103 ·- (860) 522·3343 -· JURIS NO. 20767