Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:00—cr—00239-AHN Document 126 Filed 04/11/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
pr DISTRICT OF CONNECTICUT
I UNITED STATES OF AMERICA, : CASE NO.: 3:00CR239 (AHN)
PLAINTIFF :
CRAIG BALDWIN,
DEFENDANT : APRIL 9, 2007
DEFENDANT CRAIG BALDWIN’S
MOTION TO CONTINUE DATE OF SELF SURRENDER
The defendant, CRAIG BALDWTN, through counsel, respectfuliy moves the Court
for a continuance of the date of self surrender in the above—entit1ed matter, which is currently
scheduled for May 7, 2007. In support of said motion, defense counsel represents as follows:
I. The defendant was sentenced by the Court on March 5, 2007;
2. The Court ordered the defendant committed to the custody of the U.S. Bureau
of Prisons for a term of ten (1) years, and granted the defendant’s request to
self-surrender. The Court set a self surrender date of May 7, 2007.
3. The defendant’s pararnour is due to give birth to the couples’ child during the
week of May 2l, 2007, and the defendant wants to be present at the birth, and
would like to assist his paramour once the baby is brought home. As a result,

Case 3:00-cr-00239-AHN Document 126 Filed 04/11/2007 Page 2 of 4
the defendant respectfully requests that his self-surrender date be extended to
the week of June 4, 2007.
if 4. Undersigned counsel has spoken to Assistant United States Attorney Alex
Hernandez, who has indicated that he has no objection to the defendant’s
request.
5. No prior requests for extension of time to self surrender have been filed in this
case.

Case 3:00—cr—00239-AHN Document 126 Filed 04/11/2007 Page 3 of 4
WHEREFORE, the defendant CRAIG BALDWIN respectfully requests that his
Motion to Continue Date of Self Surrender be granted.
I RESPECTFULLY SUBMITTED,
THE DEFENDANT,
CRAIG BALDWIN
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BY V Y- tj I
Bruce D. Koffsky, q.
Koffsky & Felsen, LLC I
\ 1200 Summer Street
~s¤tte 20113
Stamford, CT 06905
Tel.: 203-327-1500
Fax: 203-327-7660
Federal Bar No.: ct03772
E—mail: [email protected]

Case 3:00-cr-00239-AHN Document 126 Filed 04/11/2007 Page 4 of 4
CERTIFICATION
- THIS IS TO CERTIFY that a copy ofthe foregoing has been mailed, via U.S, Mail, Q
postage prepaid, this 9m day of April, 2007 to all counsel and pro se parties of record as n
follows:
Alex Hernandez, Esq.
Alina P. Marquez, Esq.
Assistant United States Attorneys
Office ofthe United States Attorney
915 Lafayette Boulevard
Bridgeport, CT 06604
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l ··.___ Bruce D. Koffsky .