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

Case 3:00-cr-00263-JCH

Document 1788

Filed 03/17/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT __________________________________________ : UNITED STATES OF AMERICA : : CRIM. NO. 3:00CR263 (JCH) VS. : : TODD SUMMERVILLE : March 17, 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 March 22, 2006, to April 21, 2006. In support of this motion defendant represents: 1. 2. The government has no objection to this motion being granted. This is the first motion for extension of time filed by undersigned counsel with

respect to this deadline. 3. This extension is necessary because the undersigned was appointed by the Court

of Appeals for the purpose of the appeal, and did not receive notice of the March 1, 2006, order until March 16, 2006, when the government forwarded it. The undersigned failed to file an appearance in this Court after the remand by the Court of Appeals. That appearance will be filed today, but it would seem appropriate that the Court appoint the undersigned as counsel under the terms of the Criminal Justice Act, 18 U.S.C. § 3006A.

Case 3:00-cr-00263-JCH

Document 1788

Filed 03/17/2006

Page 2 of 3

4. The undersigned needs additional time to prepare the requested submission and to review it with the defendant. 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 1788

Filed 03/17/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, on this 17th day of March 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