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

Case 3:00-cr-00263-JCH

Document 1856

Filed 11/19/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. PATRICE ST. SURIN

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CASE NO. 3:00CR263(JCH)

November 19, 2007

MOTION ON CONSENT FOR EXTENSION OF TIME The United States of America, through its undersigned Assistant United States Attorney, hereby moves this Court for an order extending the time to file the Government's memorandum in connection with the pending Crosby remand proceeding. The reason for this request is that the Government has requested a copy of the sentencing transcript from the court reporter and is awaiting a copy of that transcript. The Government's filing would otherwise be due today. This is the Government's third request for extension of time. The Government requests that the Court grant a brief extension of three weeks, through and including December 10, 2007, to file its memorandum. The Government has consulted with Bernard Kleinman, Esquire, attorney for defendant Patrice St. Surin, who has consented to the relief sought in this motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY /S/ PAUL A. MURPHY ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT26654 UNITED STATES ATTORNEY'S OFFICE 915 LAFAYETTE BOULEVARD BRIDGEPORT, CT 06604

Case 3:00-cr-00263-JCH

Document 1856

Filed 11/19/2007

Page 2 of 2

CERTIFICATION I hereby certify that on November 19, 2007, a copy of the foregoing was sent by facsimile and first class mail to the following counsel of record: Bernard V. Kleinman Two Gannett Drive, Suite 102 White Plains, NY 10604-3404 914-644-6660 Fax: 914-644-6661

/S/ PAUL A. MURPHY ASSISTANT UNITED STATES ATTORNEY