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

Case 3:00-cr-00227-SRU

Document 1473

Filed 03/29/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ------------------------------------------------- : : UNITED STATES OF AMERICA : No. 3:00 CR 227 (SRU) : v. : : RICARDO ROSARIO : March 28, 2006 : ------------------------------------------------- : DEFENDANT ROSARIO'S MOTION TO ENLARGE TIME TO SUBMIT BRIEF ADDRESSING APPELLATE REMAND Defendant, by and through his undersigned CJA counsel, respectfully requests an enlargement of time to April 10, 2006, of the currently-set deadline of March 29, 2006 to file his brief addressing the remand in the above-referenced case. In support of said motion, undersigned counsel makes the following representations: 1. Undersigned counsel has made a significant effort to re-evaluate the large

volume of materials which were available for the court's consideration when Defendant Rosario was first sentenced. While that effort is substantially complete, other trial and appellate commitments have been such that counsel has not completed that evaluation. 2. Defendant respectfully requests, therefore, the enlargement to April 10,

2006 of said deadline for submitting the brief. 3. This date undersigned counsel left a comprehensive voice mail message for

AUSA Alex Hernandez seeking the government's position. As of the time that this motion was dispatched for filing, undersigned counsel had not yet heard back from Mr.

ORAL ARGUMENT NOT REQUESTED

LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9

Case 3:00-cr-00227-SRU

Document 1473

Filed 03/29/2006

Page 2 of 3

Hernandez, but reasonably believes that the government will have no objection to the requested continuance. 4. This is defendant's fourth request for an enlargement of time to submit his

brief addressing the Appellate Remand.

Respectfully submitted, DEFENDANT RICARDO ROSARIO

By________________________________________ Robert J. Sullivan, Jr. LAW OFFICES OF ROBERT SULLIVAN 190 Main Street Westport, Connecticut 06880 Tel. No. 203/227-1404 Federal Bar No. CT08969

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LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9

Case 3:00-cr-00227-SRU

Document 1473

Filed 03/29/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy hereof was mailed on March 28, 2006 to the following: Alex V. Hernandez, AUSA U.S. Attorney's Office 915 Lafayette Blvd. Bridgeport, CT 06604 Fax: 203/579-5550

__________________________________ Robert J. Sullivan, Jr.

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LA W OFFICES OF ROBERT SULLIV A N 1 9 0 M ain St reet W est port , C T 0 6 8 8 0 T el. 2 0 3 /2 2 7 -1 4 0 4 J uris N o. 4 0 5 8 3 7 Federal Bar N o . C T 0 8 9 6 9