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

Case 3:03-cr-00251-JBA

Document 84

Filed 04/12/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA V. : : DOCKET NO. 3:03-CR 250(JBA) DOCKET NO. 3:03- CR251(JBA) APRIL 11, 2005

XIOMARA HENAO

:

REQUEST FOR AN EXTENSION TO FILE SUBSTANTIVE MOTIONS The undersigned, as counsel of record for the Defendant, hereby respectfully requests an extension of the Scheduling Order for 45 days, and in support cites the following: On or about March 30, 2005, Counsel for the Defendant was retained and promptly appeared in court. Counsel for the Defendant received discovery materials for the Defendant approximately a week later; however, due to the fact that the Defendant is housed in another state, Counsel was unable to meet with said client until April 10, 2005. Additionally, in order to avoid needless motion practice, Counsel for the Defendant has initiated pretrial negotiations with the United States; however, at this time, the parties have not yet communicated with one another. Because an extension is necessary to allow adequate time to negotiate, while protecting the Defendant's right to an adequate defense, counsel hereby requests a continuance of 45 days in which to file motions in this case. THE DEFENDANT, XIOMARA HENAO By; //s//Tina Sypek D'Amato//s// The Law Office of Tina Sypek D'Amato, LLC 135 Elm Street, Bridgeport, CT 06604 P(203) 336-2626; Fx(203) 335-0607 FB # 26252 [email protected]

Case 3:03-cr-00251-JBA

Document 84

Filed 04/12/2005

Page 2 of 2

CERTIFICATION This is to certify that the foregoing has been sent via first class mail, postage prepaid, on this 11th day of April, 2005 to the following parties of record: Mark D. Rubino U.S. Attorney's Office-NH 157 Church Street, 23rd Floor P.O. Box 1824 New Haven, CT 06510

//s//Tina Sypek D'Amato//s// Tina Sypek D'Amato, Esq.