Free Order on Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00178-RNC Document 72 Filed 06/24/2008 Pagei of4
Case 3:03-cr-00178-RNC Document 71 Filed 06/19/2008 Page 1 of4
T5
cv
$-4
<1J
U
B
8 UNITED STATES DISTRICT COURT
é DISTRICT OF CONNECTICUT
Qi UNITED STATES OF AMERICA, : CASE NO.: 3:03CR178 (RNC)
8 PLAINTIFF :
.-4 Z
J.: V. :
“$ .
cg CHAUNCEY MOORE, Z
3 DEFENDANT : June 18, 2008
Lf;
N
4.>
tg DEFENDAN T CHAUNCEY MOORE’S
gw MOTION TO CONTINUE SENTENCING
B
E The defendant, CHAUNCEY MOORE, by and through undersigned counsel,
I-i
rg respectfully moves this Court to continue his sentencing which is currently scheduled for
Jil
8 June 23, 2008 to August 25, 2008 or a date thereafter which is convenient to the Court
cu
$4
>, and Counsel, and additionally, to enlarge the dates for disclosure and response to the
.Q
'
Q\ ij Presentence Investigative Report. In support of this motion, defense counsel represents
»F·` i .
:5 as follows:
O')
E] 1. On or about March I3, 2007, the defendant pled guilty to an indictment
U ow
§ pj charging him with Unlawful Possession of a Firearm in violation of 18
¤ GS
g 5 U.S.C. §922(g). Sentencing has been scheduled for June 23, 2008. At the
. 2
to
(D 4.>
4,; E
as
Q rx
cri
0
0
N
J
N
(D
5
*1

Case 3:03-cr-00178-RNC Document 72 Filed 06/24/2008 Page 2 of 4
Case 3:03-cr-00178-RNC Document 71 Filed 06/19/2008 Page 2 of 4
time of his plea, the Court indicated to the defendant that he would have
ample time to research, brief and prepare to argue each and every point of
law he believed was necessary and appropriate in furtherance of a fair and
just sentence.
2. The undersigned counsel is currently on trial in the matter entitled
States v. Andres Bolanos, 3:07CRl3l (AWT) before the Honorable Alvin
W. Thompson, U.S.D.J. The matter, a multi-defendant narcotics
trafficking prosecution, is scheduled to continue through the second week
of July, 2008 and as such, the undersigned will not have an adequate
opportunity to prepare for Mr. Moore’s sentencing.
3. The undersigned believes that the interests of justice would be furthered
by allowing the defendant to continue his sentencing until August 25,
2008.
4. The undersigned has spoken to Assistant United States Attorney Paul
Murphy regarding the defendant’s motion, and the government does not
object to the undersigned’s request.
5. This is CHAUNCEY MOORE’s first motion for a continuance of his
sentencing date.

Case 3:03-cr-00178-RNC Document 72 Filed 06/24/2008 Page 3 of 4
Case 3:03-cr—00178—RNC Document 71 Filed 06/19/2008 Page 3 of 4
WHEREFORE, the defendant CHAUNCE MOORE respectfully requests that
his motion for a continuance of sentencing be granted.
RESPECTFULLY SUBMITTED,
THE DEFENDANT,
CHAUNCEY MOORE
BY
Bruce D. Koffsky, Esq.
Koffsky & Felsen, LLC
1200 Summer Street
Suite 20lB
Stamford, CT 06905
Tel.: 203-327-1500
Fax: 203-327-7660
Federal Bar No.: ct03772

Case 3:03-cr-00178-RNC Document 72 Filed 06/24/2008 Page 4 of 4
Case 3:03-cr-00178-RNC Document 71 Filed 06/19/2008 Page 4 of 4
CERTIFICATION
THIS IS TO CERTIFY that on June 18, 2008 a copy of the foregoing was
tiled electronically [and served by mail on anyone unable to accept electronic tiling].
Notice of this filing will be sent by e—mail to all parties by operation of the Court’s
electronic tiling system. Parties may access this tiling through the Cou1t’s system.
Bruce D. Koffsky