Free Motion for Miscellaneous Motion regarding Reduction of Sentence re Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:00-cr-00169-JCH

Document 28

Filed 07/11/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

------------------------------------------------------x : UNITED STATES OF AMERICA : : v. : : RODNEY CANADA : : ------------------------------------------------------x

Case No. 3:00CR00169(JCH)

July 11, 2008

MOTION FOR EXTENSION OF TIME The defendant, Rodney Canada, hereby requests an extension of time within which to file a reply brief in response to the Government's Memorandum dated July 2, 2008. [Doc. 27] The reply brief would normally be due on July 17, 2008, ten business days after the filing of the memorandum to which it responds. Undersigned counsel will be out of state on work-related travel for two weeks in July. The press of other business, including other crack amendment sentencing reduction cases and the matter of United States v. Yung Tang, 3:08CR00030(JBA), has prevented undersigned counsel from completing the research necessary to file an adequate response before leaving the District. Accordingly, undersigned counsel seeks an extension to and including August 4, 2008, to file an appropriate reply brief. This is the defendant's first motion for an extension of this deadline. Undersigned counsel has been unable to ascertain the position of the Government on this motion.

Case 3:00-cr-00169-JCH

Document 28

Filed 07/11/2008

Page 2 of 2

Respectfully submitted, The Defendant, Rodney Canada Thomas G. Dennis Federal Defender

Dated: July 11, 2008

__________/s/______________________ Sarah A. L. Merriam Assistant Federal Defender 265 Church Street, Suite 702 New Haven, CT 06510 Bar No. ct25379 Phone: 203-498-4200 Fax: 203-498-4207 Email: [email protected]

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 11, 2008, a copy of the foregoing motion 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/ Sarah A. L. Merriam