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

Case 3:00-cr-00227-SRU

Document 1439

Filed 01/06/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ------------------------------------------------- : : UNITED STATES OF AMERICA : No. 3:00 CR 227 (SRU) : v. : : RICARDO ROSARIO : January 5, 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 30 days, to February 6, 2006, of the currently-set deadline of January 6, 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. This honorable court's order setting the brief deadline for January 6, 2006

was issued in early December, 2005. Upon receipt, counsel undertook to retrieve the significant quantity of materials which comprised the trial and related record which existed when defendant was sentenced. In addition, counsel was away from the office during the week following Christmas. In short, additional time is needed to properly set forth the arguments to be made in the brief. 2. Defendant respectfully requests, therefore, the enlargement to February 6,

2006 of said deadline for submitting the brief. 3. AUSA Alex Hernandez has no objection to this motion being granted.

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 1439

Filed 01/06/2006

Page 2 of 3

4.

This is defendant's first 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 1439

Filed 01/06/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy hereof was mailed on January 5, 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