Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00249-RNC Document 89 Filed O1/07/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
- DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : CRIM. NO. 3:03CR249(RNC)
CHRISTINA DIXON : JANUARY 6, 2005 ‘‘‘‘
MOTION FOR CONTINUANCE OF SENTENCING
The undersigned respectfully requests that this Court continue the sentencing date in
this matter for thirty days trorn the scheduled date of January 7, 2005 for the following reasons: ·
1. The undersigned has an urgent legal matter to attend to in Buenos Aires, n
Argentina and must be in Buenos Aires, Argentina by January 8, 2005. This S
matter came to the undersigned’s attention on the afternoon of January 5, 2005. E
The undersigned immediately phoned Assistant United State’s Attorney,
Jonathan Biran and informed him of the need for a continuance. Attorney Biran
has no objection to the continuance.
2. This matter was originally set down for sentencing on November 3, 2004 before _
Chief U.S. District Judge Robert N. Chatigny. At that time Judge Chatigny
postponed sentencing until January 7, 2005 in an effort to allow the defendant U l
Rome McG·uigan, P.C. · Attorneys atLaw
One State Street · Hartford, cermeeueut 06103-3101 · :8601549-1000 · FaX(86())724-3921 · Jur1sNe.27?26 _

Case 3:03-cr-00249-RNC Document 89 Filed 01/07/2005 Page 2 of 4 1
CERTIFICATE OF SERVICE
This is to certify that on the 6th day of January, 2005, a copy of the foregoing was I
mailed, postage prepaid, via U.S. mail, to: g
Jonathan Biran, Esq.
Assistant U.S. Attomey ET
157 Church Street, 23rd Floor 7
New Haven, CT 06510
é. gan Mc n
11911-1/377672 l
Rome McGuig¤.n, PTC. · Attorneys cztLc1w g
One State Street • Hartford, Connecticut 06103-3101 • E860)549-1000 • Fax{860]724-3921 • Juris N0. 27726

Case 3:03-cr-00249-RNC Document 89 Filed O1/O7/2005 Page 3 of 4 f
time to make significant changes in her lifestyle, which would help her avoid a
jail sentence. Judge Chatigny specifically suggested that the defendant change
her living and employment status as well as continue with her drug treatment.
Judge Chatigny suggested that the defendant move back with her mother
in Simsbury, or in the least change roommates. Unfortunately, the defendant is U
unwelcome at her mother’s residence. However, since November 3, 2004 the
defendant has changed switched roommates and now lives with a female, as
requested by the Court.
The defendant has yet to succeed in securing gainful alternative
employment. Part of the defendant’s failure is due to her lack of an automobile. i
On or about November l 1, 2004, the Court granted the defendant’s request to
travel to New Mexico and retrieve an automobile from her father. Over the
Christmas week the defendant traveled to New Mexico and returned with an i
automobile. With the addition of an automobile in the defendant’s life it is Z
hoped that within the next thirty days the defendant can secure gainful
employment outside ofthe Torrington area.
The defendant has complied with the U.S. Probation office and has
remained drug free. The undersigned has spoken with U.S. Probation Officer,
Rome McGuigan, E30. · Attomeys cztLc1w
one state sneer - Harmmatcoimaeueut 06103-3101 · (S60}549-1000 · 1-raxteeotvm-aszi · Juris Ne. 2772:; ;

Case 3:03-cr-00249-RNC Document 89 Filed O1/O7/2005 Page 4 of 4 .
Katya Lopez with respect to this matter, and she has no objection to the
requested continuance.
For all ofthe reasons stated above the undersigned respectfully requests a thirty day
continuance.
ORAL ARGUMENT IS NOT REQUESTED.
DEFENDANT `/
CHRISTIN O
A. Ryan McGuigan, Esq.
Federal Bar No. CT19174 ·
Rome McGuigan Sabanosh, P.C.
One State Street Z
Hartford, CT 061036101
860-549-1000
860-724-3921 (fax)
Her Attorney
. %
Rome McGuigcm, QC. · Attorneys at Law .
One State Street · Hartford, Connecticut 06103-3101 • {860]549-1000 · Fax (860] 724-3921 · Juris No. 27726 5