Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH

Document 1921

Filed 07/19/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA Vs. TERRENCE THOMPSON, ET AL July 21, 2008 Docket No. 3:00CR263 (JCH)

MOTION FOR ENLARGEMENT OF TIME

Pursuant Procedure and

to

Rule

One

of of

the the

Local Local

Rules Rules

of of

Criminal Criminal

Rule

9(b)

Procedure, the defendant, TERRENCE THOMPSON, by and through his undersigned counsel, David J. Wenc, hereby moves for an

enlargement of time to file a motion pursuant to 18 U.S.C. Sec. 3582 until August 14, 2008. In support of this motion, the

defendant represents as follows: 1. Defense counsel has begun work on drafting a "3582" However, he needs access to

motion on behalf of Mr. Thompson.

the original trial file, which is stored off-site. 2. The storage company has indicated that the file will

be available for pick up on Monday, July 21, 2008. 3. Defense Counsel is scheduled to attend a CJA seminar

in Portland, Oregon from July 23, 2008 through July 27, 2008. 4. As a result, defense counsel will not complete the

"3582" motion by July 25, 2008, the originally scheduled filing date. Page 1 of 3

Case 3:00-cr-00263-JCH

Document 1921

Filed 07/19/2008

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5.

Instead, defense counsel believes that he can complete

the "3582" motion on or before August 14, 2008. 6. This requested extension date accounts for defense

counsel's case load as well as the importance placed on this motion by Mr. Thompson and his family. 7. This is Mr. Thompson's first request for an enlargement of time. WHEREFORE, the defendant prays that this motion be granted. Respectfully Submitted, DEFENDANT, TERRENCE 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 860-623-1195 FED BAR # CT00089

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Case 3:00-cr-00263-JCH

Document 1921

Filed 07/19/2008

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CERTIFICATION I hereby certify that on July 21, 2008 I served copy of the foregoing Motion by mailing same via U.S. mail, postage prepaid, to: Chambers of the Honorable Janet C. Hall United States District Court 915 Lafayette Boulevard Bridgeport, CT 06604 U.S. Attorney's Office 915 Lafayette Boulevard Bridgeport, CT 06604

/s/ David J. Wenc David J. Wenc, His Attorney WENC LAW OFFICES 546 Halfway House Road P.O. Box 306 Windsor Locks, CT 06096 860-623-1195 FED BAR # CT00089

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