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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. KEITH LYONS : : : CRIMINAL NO. 3:00CR263(JCH) April 21, 2008
MOTION FOR EXTENSION OF TIME The defendant, Keith Lyons, respectfully moves for an extension of time within which to file a response to the Court's Order To Show Cause, dated March 25, 2008, regarding the possible reduction of the defendant's sentence pursuant to 18 U.S.C. § 3582(c)(2) from the current deadline of April 22, 2008, to May 5, 2008. While members of the Federal Defender's Office have been in contact with Mr. Lyons, undersigned counsel has not yet had the opportunity to discuss this matter with him. Undersigned counsel is attempting to contact Mr. Lyons and obtain authorization to proceed on his behalf in connection with this matter. Mr. Lyons is currently incarcerated at the FMC Devens, and counsel is able to communicate with him only by mail. Undersigned counsel has not previously represented Mr. Lyons, and requires time to discuss the Government's position with Mr. Lyons and to file an appropriate response. Mr. Lyons is currently serving a sentence of 121 months and is subject to a mandatory minimum sentence of 120 months. Counsel has contacted Assistant United States Attorney Steve Reynolds who has no objection to this Motion for Extension of time.
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-2Respectfully submitted, THE DEFENDANT, Keith Lyons THOMAS G. DENNIS FEDERAL DEFENDER
Dated: April 21, 2008
/s/ Deirdre A. Murray Assistant Federal Defender 10 Columbus Blvd, 6th FL Hartford, CT 06106 Phone: (860) 493-6260 Bar No.: ct22981 Email: email@example.com CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on April 21, 2008, a copy of the foregoing Motion for Extension of Time was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.
/s/ Deirdre A. Murray