Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:00-cr-00203-EBB

Document 25

Filed 01/03/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. JOHN A. HACKNEY

: : CASE NO. 3:00CR203(EBB) : January 3, 2005

GOVERNMENT'S MOTION TO SUBSTITUTE MEMORANDUM IN SUPPORT OF MOTION FOR DOWNWARD DEPARTURE Comes now the United Sates, by and through its undersigned counsel, to move this Court for an Order permitting it to substitute the "Government's Revised Memorandum in Support of Motion for Downward Departure" being filed on this date for its previously submitted Memorandum dated December 27, 2004. In

support of this motion, the Government notes that its original Memorandum dated December 27, 2004 contains an error on page 14. Specifically, the last sentence of Section C on page 14 contains information unrelated to the defendant Hackney and his cooperation. WHEREFORE, the Government respectfully requests that it be

Case 3:00-cr-00203-EBB

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permitted to substitute its Revised Memorandum in support for the previously filed Memorandum dated December 27, 2004.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JOHN H. DURHAM DEPUTY UNITED STATES ATTORNEY 157 CHURCH STREET, 23RD FLOOR NEW HAVEN, CONNECTICUT 06510 (203) 821-3700 FEDERAL BAR NO. ct05087

Case 3:00-cr-00203-EBB

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CERTIFICATION OF SERVICE This is to certify that the within and foregoing has been provided this 3rd day of January 2005 by facsimile and regular mail to: Curtis L. Bowe, III c/o Law Offices of Peter C. Ensign 6925 Shallowford Road, Suite 301 Chattanooga, Tennessee, 37421 Warren Maxwell United States Probation Officer 157 Church Street, 22nd Floor New Haven, Connecticut 06510 Facsimile: 203-773-2100

JOHN H. DURHAM DEPUTY UNITED STATES ATTORNEY