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

Case 3:00-cr-00227-SRU

Document 1433

Filed 12/15/2005

Page 1 of 3

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

NO. 3:00CR227 (SRU)

DECEMBER 14, 2005

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 60 days from December 15, 2005 to February 15, 2005, 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. Counsel recently requested a copy of the entire file from the Defendant's previous attorney (Michael Hillis), in order to review and properly advise the Defendant as to how to proceed in this matter.

Case 3:00-cr-00227-SRU

Document 1433

Filed 12/15/2005

Page 2 of 3

4. Counsel understands that the file is rather large and will take a substantial amount of time to properly review all relevant documents, motions, memorandum and transcripts upon his receipt. 5. Counsel also wishes to apprise the Court that he will be traveling out of the country from December 27, 2005 to January 15, 2006.

WHEREFORE, Counsel prays that his motion for enlargement of time to February 15, 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 1433

Filed 12/15/2005

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

__________________________ Carlos E. Candal, Esq.