Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00274-CFD

Document 20

Filed 04/28/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA Criminal No. 3:03CT274(CFD) v. ANDUZE ALEXANDER April 27, 2005

CONSEN T MOTION TO CONTINUE JURY SELECTION The United States respectfully requests a one-month enlargement of time for jury selection. In support of this motion, the undersigned represents as follows: 1. 2. 3. The defendant has been released on bond living and is living in Texas. The defendant is on probation in Texas in connection with an unrelated case. The defendant has been unable to travel to Connecticut to meet with his

counsel to discuss a possible resolution of this matter because the defendant's Texas probation officer has heretofore refused to allow him to travel. 4. Defense counsel has represented that the defendant will be assigned a

different probation officer, and counsel is hopeful that the new officer will allow the defendant to travel to Connecticut. 5. 6. Jury selection is presently scheduled for May 18, 2005. Because of the circumstances discussed above, additional time is necessary

for the parties to determine whether this case can be resolved by plea agreement. 7. Defense counsel consents to the present motion.

Case 3:03-cr-00274-CFD

Document 20

Filed 04/28/2005

Page 2 of 2

Wherefore the United States requests that the Court continue jury selection for approximately thirty days. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY /s/ DAVID A. RING ASSISTANT U. S. ATTORNEY 157 Church Street P.O. Box 1824 New Haven, Connecticut 06510 (203) 821-3700 Federal Bar No. CT14362

CERTIFICATION OF SERVICE This is to certify that the within and foregoing has been sent via first-class mail this 27th day of April 2005, to: Thomas Dennis, Esq. Federal Public Defender District of Connecticut 10 Columbus Blvd., 6th Floor Hartford, Connecticut 06106

_____________/s/___________________________ DAVID A. RING ASSISTANT UNITED STATES ATTORNEY

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