Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:02-cr-00341-EBB

Document 666

Filed 05/18/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. DAVID BROWN : : : NO. 3:02CR341 EBB MAY 17, 2006

MOTION FOR CONTINUANCE OF SENTENCING David Brown, defendant, through undersigned counsel, respectfully requests that the sentencing hearing in his case which is currently scheduled for June 16, 2006, be continued 30 days. The defendant is free on bail and remains in compliance with the conditions of the Court's order of release. On or about May 9, 2006, Joseph Montesi, who is the probation officer in charge of the pre-sentence investigation and report, informed counsel that he had just received from the Government the narrative entitled "Government's Statement of Offense Conduct" accompanied by 80 pages of exhibits. This document purports to describe the trial evidence and presents the government's proposed financial loss computations for the purpose of sentencing guideines. The sentencing is currently scheduled for June 16, 2006, and Mr. Montesi informed counsel on May 16, 2006, that he should have the initial disclosure prepared by May 19, 2006. Undersigned counsel will need time to review the report and meet with the defendant and to prepare a sentencing memorandum.

Case 3:02-cr-00341-EBB

Document 666

Filed 05/18/2006

Page 2 of 2

As of May 17, 2006, the undersigned has been unable to determine the Government's position on this motion. This is the first request to continue the sentencing date in Mr. Brown's case. WHEREFORE, it is respectfully requested that the sentencing hearing be rescheduled. Respectfully submitted, DEFENDANT, DAVID BROWN

By:______________________________ Richard S. Cramer 449 Silas Deane Highway Wethersfield, CT 06109 Tel. (860) 257-3500 Federal Bar No. ct00016 Email: [email protected]