Free Motion for Departure - District Court of Connecticut - Connecticut

Case 3:00-cr-00203-EBB

Document 21

Filed 12/28/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. JOHN A. HACKNEY : : CASE NO. 3:00CR203(EBB) : December 27, 2004

GOVERNMENT'S MOTION FOR DOWNWARD DEPARTURE Pursuant to U.S.S.G. §5K1.1, the Government moves this Court for a downward departure from the applicable guideline range in light of the defendant's substantial assistance to the Government in the investigation and prosecution of other individuals. The

basis for this motion is set forth in the supporting memorandum filed this same date. 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

Document 21

Filed 12/28/2004

Page 2 of 2

CERTIFICATION OF SERVICE This is to certify that the within and foregoing has been provided this 27th day of December 2004 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