Free Motion for Extension of Time to File Response/Reply - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH

Document 1926

Filed 07/28/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA Plaintiff v. PATRICE ST. SURIN Defendant

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CRIM 3:00-cr-00263(JCH)

July 28, 2008

MOTION FOR EXTENSION OF TIME The defendant, Patrice St. Surin, hereby requests an extension of time within which to respond to the Court's Order To Show Cause. [Doc. 1889] Undersigned counsel has recently been retained by the defendant to appear in connection with this matter and has filed an appearance on July 8, 2008. Undersigned counsel has contacted United States Probation Department Senior Probation Officer Raymond Lopez regarding this matter and has is awaiting a revised PSR regarding his eligibility for a reduction of his sentence. Counsel also requires additional time to research the issue, discuss the response to the Court's order with the defendant, and file an appropriate response to the Court's order. Accordingly, undersigned counsel seeks and extension to and including September 17, 2008, to respond to the Court's Order To Show Cause. This is the defendant's second motion for extension of this deadline. The defendant's projected release date is July 2015, and it is unlikely that any reduction in his

Case 3:00-cr-00263-JCH

Document 1926

Filed 07/28/2008

Page 2 of 2

sentence would result in release in 2008 or 2009; thus, this extension of time will not prejudice Mr. St. Surin. Respectfully submitted, The Defendant By His Attorney

_________/s/__________________ Jason P. Gladstone, Esq. 46 Post Road East Suite 1 Westport, CT 06880 Juris #10402 Phone:(203) 226-8055 Fax: (203) 226-5081 E-mail: [email protected]

CERTIFICATION OF SERVICE I HEREBY CERTIFY that on July 28, 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/_______________
Jason P. Gladstone