Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:03-cr-00078-SRU

Document 91

Filed 02/07/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. KENNETH MOORE : : : CRIMINAL NO. 3:03CR28(SRU) February 6, 2007

MOTION TO ALLOW OUT-OF-STATE TRAVEL Comes now, defendant, KENNETH MOORE, through undersigned counsel, and hereby requests the Court's permission to travel out of state to Negril, Jamaica, as detailed below, to attend his wedding and honeymoon. In support of this motion, defendant states the following grounds: (1) Defendant pleaded guilty to one count of identity fraud on Friday, February 27, 2004. On May 17, 2004, the District Court sentenced the defendant pursuant to his conviction after a guilty plea. A timely appeal was taken on May 28, 2004. The case was remanded pursuant to United States v. Crosby, 397 F.3d 103 (2d Cir. 2005). The District Court Judge declined to resentence the defendant and a second notice of appeal was timely filed on November 1, 2006. Mr. Moore has subsequently completed his period of incarceration and currently resides in Aurora, Illinois. Jurisdiction remains with the District of Connecticut. (2) Defendant seeks permission to travel to Negril, Jamaica from June 27, 2007 until July 3, 2007. In order to travel to Jamaica, Mr. Moore will need to obtain a passport. (3) During his stay in Jamaica, Mr. Moore will be staying at the RIU Resort. The purpose of this trip is to attend his wedding and honeymoon. (4) Mr. Moore is currently being supervised by U.S.P.O. Michael Rowe. The undersigned counsel has been in contact with Mr. Rowe who has no objection to Mr. Moore's travel plans. Mr. Moore will surrender his passport upon his return from Jamaica. (5) Assistant United States Attorney Robert Sector defers to the judgment of the Probation Office, and accordingly, has no objection. (6) Defendant will provide all travel information as well as the address and telephone number

Case 3:03-cr-00078-SRU

Document 91

Filed 02/07/2007

Page 2 of 2

-2of the hotel where he will be staying to his supervising probation officer, Michael Rowe, and will call in as directed. (7) Prior to his incarceration, the Court granted Mr. Moore permission to travel out of state (to Virginia) to attend his child's college graduation. Mr. Moore returned according to schedule and was in full compliance with the conditions of his pre-trial release during that trip. Since his release from prison he has been in full compliance with the conditions of his supervised release. Respectfully submitted, THE DEFENDANT, KENNETH MOORE THOMAS G. DENNIS FEDERAL DEFENDER

Dated: February 6, 2007

/s/ Deirdre A. Murray Asst. Federal Defender 2 Whitney Ave., Suite 300 New Haven, CT 06510 Bar No. ct22981 (203) 498-4200 CERTIFICATION

I HEREBY CERTIFY that a copy of the foregoing Motion to Permit Out of State Travel has been mailed via facsimile and via first class mail to Robert Sector, Assistant United States Attorney, P.O. Box 1824, New Haven, CT 06508, and to United States Probation Officer Michael Rowe, on this 6th day of February, 2007.

/s/ Deirdre A. Murray