Free Motion for Release from Custody - District Court of Connecticut - Connecticut

Case 3:03-cr-00253-SRU

Document 74

Filed 04/28/2005

Page 1 of 1

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT _______________ UNITED STATES OF AMERICA VS. SALVATORE J. CARTELLI, JR. APRIL 25, 2005 3:03cr253 (SRU) 3:03cr182 (SRU)

MOTION FOR RELEASE PENDING APPEAL Pursuant to rule 46(c) of the Federal Rules of Crim. Procedure, and 18 U.S.C. 3143(b), Defendant moves that he be released on bond pending completion of his pending appeals in each of the above matters. Without such relief it is likely that the Defendant would be released from custody having served his appropriate sentence before his appeals are completed.

THE DEFENDANT, SALVATORE J. CARTELLI, JR. BY__________________________________ JONATHAN J. EINHORN 412 Orange Street New Haven, CT 06511 (203) 777-3777 CT 00163 CERTIFICATION This is to certify that a copy of the foregoing was mailed, postage prepaid this 25th day of April, 2005 to the following: Calvin Kurimai, Esq., Assistant U.S. Attorney,157 Church Street, New Haven, CT 06510 and William Paetzold, Esq., 140 Hebron Avenue, Suite 102 Glastonbury, CT 06033.

_______________________________ JONATHAN J. EINHORN