Case 3:00-cr-00077-JCH
Document 104
Filed 04/01/2008
Page 1 of 2
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. LAWRENCE VELEZ : : : : : Case No. 3:00CR00077(JCH)
April 1, 2008
MOTION FOR EXTENSION OF TIME The defendant, Lawrence Velez, hereby requests an extension of time within which to file a response to the Court's Amended Order To Show Cause, dated March 28, 2008, regarding the possible reduction of the defendant's sentence pursuant to 18 U.S.C. ยง 3582(c)(2) from the current deadline of April 8, 2008, to April 21, 2008. Undersigned counsel is attempting to contact Mr. Velez and obtain authorization to proceed on his behalf in connection with this matter. Mr. Velez is currently incarcerated at the Brooklyn Metropolitan Detention Center, and counsel is able to communicate with him only by mail. Undersigned counsel has not previously represented Mr. Velez, and requires time to discuss the Government's recommendation with Mr. Velez and to file an appropriate response. Respectfully submitted, The Defendant, Damon Graham Thomas G. Dennis Federal Defender
Dated: April 1, 2008
__________/s/______________________ Sarah A. L. Merriam Assistant Federal Defender 265 Church Street, Suite 702 New Haven, CT 06510 Bar No. ct25379 Phone: 203-498-4200 Fax: 203-498-4207 Email: [email protected]
Case 3:00-cr-00077-JCH
Document 104
Filed 04/01/2008
Page 2 of 2
CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 1, 2008, a copy of the foregoing motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. /s/ Sarah A. L. Merriam