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

Case 3:00-cr-00227-SRU

Document 1453

Filed 02/14/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. FELIPE SANTANA : : : : :

NO. 3:00CR227 (SRU)

FEBRUARY 13, 2006

MOTION FOR ENLARGEMENT OF TIME FOR DEFENDANT TO REVIEW AND CONSIDER WHETHER TO FILE A REQUEST FOR RESENTENCING TO A NON-TRIVIALLY DIFFERENT SENTENCE Now comes the defendant, FELIPE SANTANA, by and through his attorney, Carlos E. Candal, and hereby moves this Honorable Court to allow the defendant an enlargement of time of 45 days from February 15, 2006 to March 30, 2006, to appropriately determine whether to file a request, motions, and/or memorandum for this court to review and consider re-sentencing defendant to a non-trivially different sentence, for the following reasons: 1. As a result of the remand from the Court of Appeals, the Defendant's case is before this Court to determine if it would have imposed a non-trivially different sentence if the Sentencing Guidelines had been advisory. 2. Counsel was recently appointed as a C.J.A. in this matter, and filed his appearance on November 1, 2005. 3. On January 27, 2006, Counsel received a significant portion of the Defendant's file from the defendant's previous attorney (Michael Hillis), in

Case 3:00-cr-00227-SRU

Document 1453

Filed 02/14/2006

Page 2 of 3

order to review and properly advise the Defendant as to how to proceed in this matter. 4. Counsel notes that the file is rather large and will take a substantial amount of time to properly review all relevant documents, motions, memorandum and transcript. 5. Counsel also needs additional time in order to adequately communicate his findings and strategy with the defendant, who is located at the Federal Correctional facility in Bradford, PA. WHEREFORE, Counsel prays that his motion for enlargement of time to March 30, 2006 be granted, and that he be given additional time within which to file any requisite motions and/or sentencing memorandums.

Respectfully Submitted THE DEFENDANT FELIPE SANTANA BY__________________________________ CARLOS E. CANDAL Federal Bar No. ct18667 Law Offices of Carlos E. Candal, LLC 205 Church Street, Suite 306 New Haven, CT 06510 (203) 562-3000 FAX: (203) 772-3726 His Attorney

Case 3:00-cr-00227-SRU

Document 1453

Filed 02/14/2006

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that a copy of the foregoing motion was mailed on this date to the following: A.U.S.A. Alina Reynolds 915 Lafayette Blvd. Bridgeport, CT 06604 Felipe Santana Inmate # 14056-014 Federal Correctional Institution McKean P.O. Box 8000 Bradford, PA 16701

__________________________ Carlos E. Candal, Esq.