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

i - 5e•3;OO-cr-OO22Za®RU Document 1465 Filed OS/0%/2006 Page 1. of 3
UNITED STATESI OU T
DISTRICT OF CONN
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UNITED STATES OF AMERICA No. 3:00 CR 227 (SRU} I
RICARDO ROSARIO March 7, 2006
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_I_§>_Ij§‘ENDANT ROSARIO’S MOTION TO ENLARGE TIME E
Tg SUBMIT BRIEF ADDRESSING APPELLATE REMAND
Defendant, by and through his undersigned CJ A counsel, respectfully requests an I
enlargement of three weeks, to March 29, 2006, of the currently-set deadline of March
_ 8, 2006 to file his brief addressing the remand in the above-referenced case. In support I
of said motion, undersigned counsel makes the following representations: 6 I
1. Undersigned counsel has made a significant effort to re—eva1uate the large
volume of materials which were available for the court’s consideration when Defendant
I 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 March 29,
2006 of said deadline for submitting the brief. I
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. I
Hernandez, but reasonably believes that the government will have no objection to the I
requested continuance. l
LAW OFFICES OF ROBERT SULLIVAN 190 Main Street Westport, CT 06880 Tel. 203r'227-1404 Juris Nu. 405837 Federal Bar N¤.CT08969 I
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. ase`3:OO—cr-OO22@@RU Document 1465 Filed O@2006 Page 2 of 3
i 4. This is defendant’s third request for an enlargement of time to submit his
brief addressing the Appellate Remarid. E
Respectfully submitted, l
DERENDANT RICARDO ROSARIO E
i By i
L Robert J. S llivari, Jr.
F LAW om ES or ROBERT surrivlm
y 190 Main treet
l Westport, Connecticut 06880
Tel. No. 203/227-1404
p Federal Bar No. CT08969
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_. LAW OFFICES OF ROBERT SULLIVAN 190 Main Street Westport, CT 06880 Tel. 203/227-1404 Juris Nu. 405837 Federal Bar No.CTO8969 l
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( Q * se*3:OO-cr-0022K-[EQU Document 1465 Filed O3@2006 Rage 3.of 3 i
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CERTIFICATION _
This is to certify that a copy hereof was mailed on March 7, 2006 to thefollowingc
Alex V. Hemandez, AUSA
- U.S. Att0rney‘s Office
915 Lafayette Blvd. ’
i Bridgeport, CT 06604 l
f Fax: 203/579-5550 . p
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Robert J. §u1livan, Jr. l
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LAW OFFICES OF ROBERT SULLIVAN 190-Main Street Westport, CT 06880 Tel. 203/227-1404 Juris No. 405837 Federal Bar N¤.CTO8969
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