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

Case 3:00-cr-00263-JCH

Document 1792

Filed 04/21/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT __________________________________________ : UNITED STATES OF AMERICA : : CRIM. NO. 3:00CR263 (JCH) VS. : : TODD SUMMERVILLE : April 19, 2006 __________________________________________: MOTION TO EXTEND TIME TO FILE MEMORANDUM The defendant in the above-captioned matter hereby moves extend the time for the parties to file simultaneous submissions as to whether the Court would have imposed a nontrivially different sentence if the Sentencing Guidelines had been advisory, from April 21, 2006, to May 19, 2006. In support of this motion defendant represents: 1. 2. The government has no objection to this motion being granted. This is the second motion for extension of time filed by undersigned counsel

with respect to this deadline. 3. This Court appointed the undersigned about one month ago with respect to this

issue. The undersigned has obtained such records and supporting materials as are readily available, and is reviewing other materials. However, a very difficult discovery deadline in another case, which has required out of state travel each week this month, has severely limited the time available to complete this work.

Case 3:00-cr-00263-JCH

Document 1792

Filed 04/21/2006

Page 2 of 3

4. The undersigned needs additional time to prepare the requested submission and to review it with the defendant, particularly in light of his incarceration in New York. 5. There is no known unfair prejudice to any party if this motion is granted.

THE DEFENDANT

By________________________________ William M. Bloss, No. ct01008 Koskoff Koskoff & Bieder, P.C. 350 Fairfield Avenue Bridgeport, CT 06604 TEL: 203-336-4421 FAX: 203-368-3244 email: [email protected]

Case 3:00-cr-00263-JCH

Document 1792

Filed 04/21/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, on this 19th day of April 2006, to all counsel and pro se parties of record, as follows: Paul Murphy, Esquire Assistant U.S. Attorney 915 Lafayette Blvd. Bridgeport, CT 06604 ________________________________ William M. Bloss