Free Motion for Disclosure - District Court of Connecticut - Connecticut

Case 3:00-cr-00263-JCH Document 1852 Filed 10/25/2007 Page 1 of 3
UNITED STATES DISTRICT COIEE gr.,
DISTRICT OF CONNECTIZBUTUCI 2 5 D 2: 57
UNITED STATES OF AMERICA : CH)
PATRICE ST- SURIN October 25, 2007
MOTION ON CONSENT FOR DISCLOSURE AND ADDITIONAL TIME
The United States of America, through its undersigned Assistant United States Attorney,
hereby moves this Court for an order permitting U.S. Probation to tum over a copy of the
presentence report ("PSR") in the above—referenced matter to the Government so that the
Government may draft and tile a memorandum in connection with the pending Crosby remand
proceeding. In addition, the Government seeks additional time to file such a memorandum in
this matter. In support, the Government notes the following: _
This case was part of a larger multi-defendant case before this Court. The attorney for the
Government who was primarily responsible for this matter has left the U.S. Attorney’s Office,
and the undersigned Assistant United States Attomey is unfamiliar with all the facts of this
defendant’s case. The Government’s tiles relating to the overall investigation and prosecution
are voluminous, and the undersigned has not located the PSR relating to this defendant. The
Probation office is in a position to provide the undersigned with a copy of the PSR, but requires
an order from the Court to do so. Accordingly, the Government requests an order permitting
Probation to make such disclosure of the PSR to the Government.
Because the undersigned has not yet reviewed all the information needed to file an
appropriate memorandum here, the Government further requests that the Court grant a brief

Case 3:00-cr-00263-JCH Document 1852 Filed 10/25/2007 Page 2 of 3
extension of three weeks, through and including November 19, 2007, to file the Govern1nent’s
Crosby remand submission, which is currently due on Monday, October 29, 2007. This is the
Govemment’s second request for an extension of time. A
The Government has consulted with Bemard Kleinman, Esquire, attorney for defendant
Patrice St. Surin, who has consented to the relief sought in this motion. To the extent the Court
permits the defendant to file a reply to the Govemment’s memorandum, the Government will
have no objection to defense counsel being granted sufficient time to file such a reply.
Respectfully submitted,
KEVIN J. O’CONNOR
UNIT TES AT RNEY
*’ L
A i I A mmf
PAUL A. Y
ASSISTANT UNITED STATES ATTORNEY
FEDERAL BAR NO. CT26654
UNITED STATES ATTORNEY’S OFFICE
915 LAFAYETTE BOULEVARD
BRIDGEPORT, CT 06604
(203) 696-3000
(203) 579-5575 (fax)
2

Case 3:00-cr-00263-JCH Document 1852 Filed 10/25/2007 Page 3 of 3
CERTIFICATION
I hereby certify that on October 25, 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

PAUL A. / ‘
ASSISTANT UNITED/§1`ATES ATTORNEY