Free Motion for Miscellaneous Motion regarding Reduction of Sentence re Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:02-cr-00300-AVC

Document 92

Filed 04/28/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. HERIBERTO BATIZ APRIL 23, 2008 NO. 3:02cr300 (AVC)

MOTION OF DEFENDANT HERIBERTO BATIZ RE: REDUCTION OF SENTENCE CRACK COCAINE OFFENSE 18 U.S.C. § 3582 Defendant Heriberto Batiz, in the above-captioned criminal matter, through counsel, respectfully moves the Court hereby to reduce the sentence imposed upon him by the Court on March 11, 2004, pursuant to 18 U.S.C. §3582 and the recent amendments to the sentencing guidelines governing crack cocaine offenses. In its Addendum, the Probation Office concludes that the difference in sentencing range is 21-27 months with a revised release date after the reduction called for by the amended guidelines of August 6, 2011. WHEREFORE, in light of the foregoing, and the Addendum prepared by and submitted by the United States Probation Office, Defendant respectfully moves this Court to grant this motion to reduce Defendant's sentence pursuant to 18 U.S.C. §3582 and in light of Amendment 706 to the United States Sentencing Guidelines.

Case 3:02-cr-00300-AVC

Document 92

Filed 04/28/2008

Page 2 of 2

Defendant respectfully moves that his motion be granted. RESPECTFULLY SUBMITTED, DEFENDANT, HERIBERTO BATIZ BY ______________________ JONATHAN J. EINHORN, ESQ. 412 ORANGE STREET NEW HAVEN, CONNECTICUT 06511 203-777-3777 FEDERAL BAR NO. ct00163 CERTIFICATION I hereby certify that on April 23, 2008, a copy of the foregoing Motion was mailed, postage prepaid to the following counsel of record:

Henry K. Kopel U.S. Attorney's Office 157 Church St., PO Box 1824 23rd Floor New Haven, CT 06510 John A. Danaher, III U.S. Attorney's Office 450 Main St. Room 328 Hartford, CT 06103
Keith Barry U.S. Probation Office 915 Lafayette Boulevard Bridgeport, Connecticut 06604

___________________________ JONATHAN J. EINHORN