Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:00-cr-00167-DJS

Document 304

Filed 04/11/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA,
Plaintiff,

Criminal

No.OOCR167

(DJS)

v.
SHATINA PARKER

Defendant.
MOTION TO CLARIFY

April

7

THE RECORD & CORRECT THE SENTENCE

1.

Pursuant
SHATINA

to

Fed.R.Crim.P.

Rule
her

36,

the

defendant,

PARKER,

by and through
Honorable sentence,

attorney,

David

J

Wenc, hereby
record

moves the the record to
time

Court

to

clarify

the

and correct the

as follows:

a. Clarify not

to

indicate Ms. Parker when it for

that
the

the

court

did
to to

intend
\\

deprive
II

opportunity Parker

earn

good -

credit

sentenced

a term of imprisonment
b. Correct

12 months.

the
(12

judgment

to

reflect

a sentence This correction

of

one
will

year

months)

and one day.

implement

the of the

court's

intention

not to earn

deprive

Ms

Parker credit
2. Defendant's

opportunity

"good-time"

counsel

left

a voice this

mail

message with

AUSA

Nora Dannehy regarding

motion;

however,

he has not

heard

back

from AUSA Dannehy as of
1

the

date

of

this

Case 3:00-cr-00167-DJS

Document 304

Filed 04/11/2005

Page 2 of 3

motion.

Therefore,

he does not

know the position

of

the government

3.

Defendant's

counsel

received

a telephone that

message she objected

from
to

USPO Charmaine
this motion.

Harkins,

who stated

WHEREFORE,

the defendant

prays

that

this

motion

be granted.

Respectfully Submitted, DEFENDANT, SHATINA PARKER,

BY
Wenc

Q~/ Jnwen?, Her Attorney
Lafl Offlces

q~.~

44 Main Street P.o. Box 306 Windsor Locks, CT 06096 Tel. (860) 623-1195 FED BAR # CTOO089

2

Case 3:00-cr-00167-DJS

Document 304

Filed 04/11/2005

Page 3 of 3

CERTIFICATION

I hereby certify the foregoing Motion postage prepaid, to:

that on April 7, 2005, I served a copy of by mailing same via u.s. mail, first-class, J. Squatrito

Chambers of the Honorable Dominic United States District Court 450 Main Street Hartford, CT 06103

Assistant U.S. Attorney Nora Dannehy U.S. Attorney's Office 450 Main Street, Rm. 328 Hartford, CT 06103 USPO Charmaine Harkins U.S. probation Office 450 Main Street, 7th Floor Hartford, CT 06103

~~--£:re

~