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

Case 2:85-cr-00050-AVC Document 78 Filed 05/01 /2008 Page 1 of 3
UN{TED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : CRIMINAL NO. 2:85CR50(AVC)
AVELINO GONZALEZ CLAUDIO May 1, 2008
DEFENDANTS MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE OPPOSITION TO THE GOVERNMENTS
MOTION FOR DESIGNATION AS COMPLEX CASE
Pursuant to Local Criminal Rule 1 and Local Civil Rule 7(b), the Defendant, Avelino
Gonzalez Claudio, respectfully requests that this Court grant him an extension of time within
which to tile his opposition to the Govermnenfs Motion for Designation as Complex Case
Warranting Excludable Time Under Speedy Trial Statute. The Government does not object to
this request. Undersigned counsel submits that the following facts represent good cause
justifying an extension of time until Monday, May 5, 2008:
1. The Government filed its motion on Aprii 10, 2008.
2. The Defendant’s opposition brief is due on May I, 2008. `
3. Undersigned counsel is responsible for filing the Defendanfs opposition brief
and has researched the issues and is presently drafting the opposition.
4. Undersigned counsel has been subpoenaed to testify in a state court matter on
May 1, 2008 and is anticipated to be absent from the ofiice for several hours,

Case 2:85-cr-00050-AVC Document 78 Filed 05/O1/2008 Page 2 of 3
and therefore will be unable to finish drafting the brief by the end of business on ·
May 1.
WHEREFORE, based on the foregoing reasons, Mr. Gonzalez Claudio respectfully
requests that this Court grant this Motion for Extension of time until Monday, May 5, 2008.
DEFENDANT,
AVELI O GONZALEZ
cr,.-I gy, r M .
` ' . 9 ./. . » .---

Moir L. Bu e , Esq.
Federal Bar No. et18803
James W. Bergenn Esq.
Federal Bar No. ct 00006
Morgan P. Rueckert, Esq.
Federal Bar No. ct 19838
Shipman & Goodwin LLP
One Constitution Plaza `
Hartford, CT 06103
Tel; (860) 251-5836
Fax: (860) 251-5219
[email protected]
His Attorneys
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Case 2:85-cr-00050-AVC Document 78 Filed 05/O1/2008 Page 3 of 3
CERTIFICATION OF SERVICE
I hereby certify that a copy ofthe foregoing was mailed, via U.S. Mail, postage
prepaid, on this lst day of May, 2008, to:
Henry K. Kopel, Esq. ,
Assistant United States Attorney
Office of the United States Attorney
157 Church Street, 23*** Floor
New Haven, CT 06510
Paul McConnell
Assistant United States Attorney .
Office of the United States Attorney
450 Main Street
Hartford, CT 06103
01ra . B kl y
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