Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:02-cr-00081-JBA

Document 315

Filed 11/19/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA

v. PATRICK A. TRIUMPH

: : : : : : : : :

CRIMINAL NO. 3:02CR81(JBA)

NOVEMBER 19, 2004

THE UNITED STATES' MOTION FOR EXTENSION OF TIME TO FILE SENTENCING MEMORANDUM The United States hereby moves for a one (1) week extension of time until November 30, 2004 to file its sentencing memorandum in the above-captioned matter. In motions already filed with the Court, the defendant has raised many issues pertaining to his sentencing, including several claimed bases for downward departure, and while the undersigned has made progress in researching the issues raised, additional time is required to complete the sentencing memorandum. The undersigned is also in the process of preparing replies to a multitude of post-trial motions that defendant has filed in the past several weeks. This Court is scheduled to sentence defendant December 15, 2004 and the extension sought will not create any delay in the sentencing. The United States will file any reply to the defendant's sentencing brief by December 7 as originally contemplated by the Court. The undersigned has been unable to ascertain the defendant's position with respect to this motion. To the extent that defendant might need additional time for a reply, the United States certainly has no

Case 3:02-cr-00081-JBA

Document 315

Filed 11/19/2004

Page 2 of 3

objection to a reasonable extension. This is the first such request with respect to this deadline.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

S. DAVE VATTI ASSISTANT UNITED STATES ATTORNEY Fed. Bar No. ct11957 450 Main Street, Room 328 Hartford, CT 06103 860-947-1101

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Case 3:02-cr-00081-JBA

Document 315

Filed 11/19/2004

Page 3 of 3

CERTIFICATION This is to certify that a true copy of the foregoing has been sent via United States mail, first class, postage pre-paid on the 19th day of November 2004 to: Mr. Patrick A. Triumph Reg. No. 14622-014 State ID 313641 Corrigan-Radgowski Correctional Center 986 Norwich-New London Turnpike Uncasville, CT 06382 Norman A. Pattis, Esq. Williams & Pattis 59 Elm Street New Haven, CT 06510

____________________________ S. Dave Vatti Assistant United States Attorney

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