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

Case 3:00-cr-00075-AWT

Document 278

Filed 10/07/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. KENNETH HAWKINS : : : : : CRIMINAL NO. 3:00CR75(AWT) CIVIL NO. 3:05CV1186(AWT) October 6, 2005

UNITED STATES' SECOND MOTION FOR EXTENSION OF TIME On or about August 10, 2005, the Court issued an Order requiring the Government to file a response to the petition of Kenneth Hawkins. The Government's response must explain why the

relief prayed for in the petition should not be granted, and was initially due on September 14, 2005. On or about September 7, 2005, the Government requested that the Court grant an extension of 30 days, allowing the Government's response to be filed on or before October 14, 2005. was granted. This motion

The Government now moves for a second continuance of In support of this

30 days, up to and including November 14, 2005.

motion, the United States represented as follows: 1. Counsel for the Government selected a jury in United

States v. Riccitelli, 3:04CR28(JBA), on October 5, 2005. The trial is expected to last until the last week of October. This case

involves allegations of Racketeering and Racketeering Conspiracy. The matter initially involved over a dozen defendants, all of whom have pleaded guilty but one. The remaining defendant appeared in However, the In short, when

court on September 29, 2005, to plead guilty. defendant ultimately elected to not plead guilty.

Case 3:00-cr-00075-AWT

Document 278

Filed 10/07/2005

Page 2 of 2

-2counsel filed the first request for an extension in this case, it was reasonably anticipated that the matter of United States v. Riccitelli would not proceed to trial. 2. 3. This is the second request for an extension of time. The undersigned has not been able to ascertain the

petitioner's position regarding this request for a thirty day extension, but expects that an objection will be lodged. Wherefore the United States requests that the Court continue the filing of a response brief until November 14, 2005. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

MICHAEL J. GUSTAFSON ASSISTANT UNITED STATES ATTORNEY 157 Church Street New Haven, Connecticut 06510 Federal Bar No. CT01503 CERTIFICATION OF SERVICE This is to certify that the within and foregoing has been mailed, via first-class mail, this _____ day of October 2005, to: Kenneth Hawkins Reg # 04844-070 Dorm 210 Duluth Federal Prison Camp PO Box 1000 Duluth, MN 55814 ________________________________ MICHAEL J. GUSTAFSON ASSISTANT UNITED STATES ATTORNEY