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

Case 3:00-cr—00203-EBB Document 32 Filed 01/21/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA
Crim. N0. 3:00-CR-00203(EBB)
v.
Violation: Title 18, United States
Code §1962(d) [RICO Conspiracy]
JOHN HACKNEY
MOTION FOR EXTENSION OF TIME TO REPORT TO BUREAU OF
CORRECTIONS
Defendant John Hackney, by counsel, respectfully moves this Court for an
extension of time in which to report to the Bureau of Corrections. Specifically, on or
about January 15, 2005, John Hackney injured himself accidentally, in a fall causing a
break in his thoracic vertebrae and a head injury.
Currently, Dr. John Boggess treats Mr. Hackney’s injuries and is concerned that
Mr. Hackney’s age and injuries will prevent any immediate travel. (See Exhibit A
attached hereto, Dr. Boggess’ medical statement and medical records). Mr. Hackney is
scheduled to report to Yazoo City, Mississippi to begin his sentence of imprisonment
conferred by this Court on January 4, 2005 and entered on January 10, 2005.
Because of: (i) his current medical condition, (ii) his therapeutic recovery time,
and (iii) his physician’s concern over the extent of and potential damage to his delicate
injury, Mr. Hackney respectfully requests that the Court grant him an extension of time in
which to report to his designated facility to begin serving his sentence of imprisonment
including and up to eight (8) weeks or March 22, 2005.

Case 3:00-cr—00203-EBB Document 32 Filed 01/21/2005 Page 2 of 2
Respectfully submitted,
ANDREWS & BOVVE, PLLP
By:CurZis L. Bowe, HI
Curtis L. Bowe, III
TN BPR 017037
P.O. Box 81023
Chattanooga, Tennessee 37414
Office: (423) 593-3536
Attorneys for John Hackney
Dated: January 20, 2005
CERTIFICATE OF SERVICE
The undersigned hereby certifies that an exact copy of the foregoing has been sent
to Mr. John Durham, Assistant United States Attorney, New Haven Office Connecticut
Financial Center 157 Church Street, Floor 23, New Haven, Connecticut 06510 on this the
20th day of January, 2005.
Curtis L. Bowe, HI
Curtis L .Bowe, III
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