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

_ _ se 3:00-cr-00227-SRU Document 1488 Filed 05/11/2006 Page 1 of 3 :
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UNITED STATES DISTRICT __€»
DISTRICT OF CONNECTI6,5g.JI[MI I I {D lg, 2q I
UNITED STATES OF AMERICA : _ };00@l227(SRU)
VS. : I Yi`) ;;,.*, L,
EDWARD ESTRADA : MAY 9, 2006
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MOTION FOR ENLARGEMENT OF TIME FOR RE-SENTENCING l
Pursuant t0 Rule 45(b) 0f the Federal Rules 0f Criminal Procedure, Defendant l
- EDWARD ESTRADA, by and through his undersigned counsel, hereby requests
an enlargement 0f time for sentencing until the third week in June, 2006. He
represents in support of said motion:
1) On September 9, 2002, the Defendant was sentenced to a term of life
without release.
2) On or about April 11, 2003, he filed his appealed with the Second Circuit.
3) The case was remanded by the Second Circuit in accordance with }_J_l_@
States v. Crosby . l
4) On August 22, 2005, the trial court determined that, had the Sentencing
Guidelines been advisory, it “would have imposed a non-trivially different sentence
on Edward Estrada?
5) On October 14, 2005, his re-sentencing hearing was begun before the
Honorable Stefan R. Underhill. I
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6) The re-sentencing hearing is scheduled to resume May 12, 2006. j
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7) On May 9, 2006, Assistant United States Attorney Alina Reynolds '
telephoned undersigned counsel; AUSA Reynolds said she would not be able to go I
forward on May 12 because she is currently on trial in a multi-defendant case.
8) AUSA Reynolds requested that undersigned counsel file a motion for
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enlargement of time until mid-June, when the government will be ready to proceed
with the re-sentencing hearing.
_ 9) Counsel has since spoken with the Defendant by telephone; he is in
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agreement with the filing of the motion for enlargement of time. A

WHEREFORE, the Defendant respectfully requests that his sentencing be continued
until the third week in June, 2006. E
DEFENDANT, EDWARD ESTRADA
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BY r
MA G ET P. LEVY |
Federal Bar No. ct00045 l
His Attorney
21 Oak Street _
Hartford, CT 06106-8001 l
(860) 525-9ll9 l
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CERTIFICATION R
THIS IS TO CERTIFY that a copy 0f the foregoing was mailed this day, y
postage pre—paid, or was hand-delivered to the following: 5
Hon. Stefan R. Underhill
United States District Court
915 Lafayette Boulevard _ i
Bridgeport, CT 06604 ‘
Alina Reynolds
Assistant United States Attorney
915 Lafayette Boulevard _
Bridgeport, CT 06604 y
Edward Estrada
Reg. No. 60392-053 _
FDC—Wyatt
950 High Street ·
Central Falls, Rl 02863
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MA G ET P. LEVY
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