Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00178-RNC

Document 71

Filed 06/19/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, PLAINTIFF V. CHAUNCEY MOORE, DEFENDANT : : : : : : : CASE NO.: 3:03CR178 (RNC)

June 18, 2008

DEFENDANT CHAUNCEY MOORE'S ____MOTION TO CONTINUE SENTENCING____

The defendant, CHAUNCEY MOORE, by and through undersigned counsel, respectfully moves this Court to continue his sentencing which is currently scheduled for June 23, 2008 to August 25, 2008 or a date thereafter which is convenient to the Court and Counsel, and additionally, to enlarge the dates for disclosure and response to the Presentence Investigative Report. In support of this motion, defense counsel represents as follows: 1. On or about March 13, 2007, the defendant pled guilty to an indictment charging him with Unlawful Possession of a Firearm in violation of 18 U.S.C. §922(g). Sentencing has been scheduled for June 23, 2008. At the

Case 3:03-cr-00178-RNC

Document 71

Filed 06/19/2008

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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 United States v. Andres Bolanos, 3:07CR131 (AWT) before the Honorable Alvin W. Thompson, U.S.D.J. The Bolanos 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 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 201B Stamford, CT 06905 Tel.: 203-327-1500 Fax: 203-327-7660 Federal Bar No.: ct03772

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 filed electronically [and served by mail on anyone unable to accept electronic filing]. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

__________________________________________________ Bruce D. Koffsky