Free Docket Annotation - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH

Document 1953

Filed 09/11/2008

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, V. Plaintiff, Criminal No. 3:00CR-263(JCH)

TERRANCE THOMPSON, Defendant. September 9, 2008

MOTION FOR PERMISSION TO FILE A SUR-SUR-REPLY BRIEF NOW comes the defendant, TERRANCE THOMPSON, by and through his attorney, David J. Wenc, and moves this Honorable Court, for permission to file a sur-sur-reply brief in order to address the arguments put forth by the government in its sur-reply brief dated September 8, 2008. The purpose of this sur-sur-reply brief is two-fold: (1) address the government's acceptance of Mr. Thompson's argument that he was sentenced "based on" USSG Section 2D1.1; and (2) present the court with a recent United States District Court decision that a motion for a reduction in sentence pursuant to 18 USC Section 3582(c) can form the basis for a de novo review of a defendant's sentence after considering the factors set forth in 18 USC Section 3553. WHEREFORE, the defendant prays that this motion be granted. Respectfully Submitted, DEFENDANT, TERRANCE THOMPSON,

BY: /s/ David J. Wenc David J. Wenc, His Attorney WENC LAW OFFICES 546 Halfway House Road P.O. Box 306 Windsor Locks, CT 06096-0306 Tel. (860) 623-1195 Fed. Bar ct00089 Page 1 of 2

Case 3:00-cr-00263-JCH

Document 1953

Filed 09/11/2008

Page 2 of 2

CERTIFICATION I hereby certify that on September 9, 2008 I served a copy of the foregoing Motion for Permission by CMECF and/or U.S. mail, first-class, postage prepaid, to: Chambers of the Honorable Janet C. Hall United States District Court 915 Lafayette Boulevard Bridgeport, CT 06604 Assistant United States Attorney Stephen Reynolds Office of the U.S. Attorney 157 Church Street, 23rd Floor New Haven, CT 06510 Terrance Thompson, Inmate #14264-014 C/o FCI Allenwood Medium Federal Correctional Institution P.O. BOX 2000 White Deer, PA 17887

/s/ David J. Wenc David J. Wenc, Esquire

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