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

Case 3:00-cr-00227-SRU Document 1441 Filed O1/O9/2006 Page 1 of 3
UNtTI-ED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNiTED STATES OF AMERICA ; CRSM. NO. 3:00c:r227SRU)
V. :
FELIX DEJESUS : JANUARY 9, 2006
DEFENDANTS ¥I!IOTiON FOR EXTENSION OF TIME
Defendant Felix Detiesus hereby moves for a two week extension of time
to submit a written Memorandum on the question of re-sentencing fotlowing the
remand of this case from the Second Circuit pursuant to USA v. Crosby, 397
F.3d 303 (2"d Cir. 2005). In support of this motion, the undersigned represents
the foiiowingi
1. The defendant was convicted of narcotics offenses totlowing a jury trial
in i\/larctr 2002.
2. In September 2002, the defendant was sentenced to a term of
imprisonment of 30 years.
3. The defendant appealed the conviction and the sentence. On
November 29, 2005, the Second Circuit Court of Appeais affirmed the conviction
but remanded the case to the District Court for further sentencing proceedings
pursuant to USA v. Crosby, 397 F.3d 103 (2'id Cir. 2005).
4. On or about December 6, 2005, the District Court issued an order
directing that any written memoranda on the question of re-sentencing be
submitted to the Court on or before January 6, 2006.
5. Defense counsel intends to submit a written memorandum to the Court
and requests a short extension of time to do so. The memorandum is partially

Case 3:OO—cr-00227-SRU Document 1441 Filed O1/O9/2006 Page 2 of 3
drafted but additional time is required to review the record of the original
sentencing proceedings and to conduct additional legal research.
6. Government counsel has been consulted regarding the requested
extension of time and the Government has no objection to the request.
7. This is the defendant’s first request for an extension of time with
respect to this fliing deadiine.
WHEREFORE, defendant Felix Dedesus respeclfuiiy requests that the
time for the defendant to submit a written Memorandum being extended to and
including January 20, 2008
Ti-iE DEFENDANT:
Bv._..;__.......................,...,,
Dan E. LaBelie of
I-IALLORAN 8. SAGE LLP
Fed. Bar #ct 1984
315 Post Road West
Westport, CT 06880
(203) 227-2855
label|e@hal|oran-sagercom

Case 3:00-cr—OO227—SRU Document 1441 Filed O1/O9/2006 Page 3 of 3
Certification of Service
This is to certify that on this 9th day of January, 2006, a copy of the
foregoing Motion for Extension of Time was delivered by hand to the following
counsel of record:
Alex Hernandez, Esq.
Alina Reynolds, Esq,
Assistant tJ,S. Attorneys
Lafayette Bouievard
Bridgeport, CT
Dan E, LaBelEe