Free Motion to Continue - District Court of Connecticut - Connecticut

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Case 3:03-cr—00€%—RNC Document 123 Filed 0558/2005 Page 1 of 3
UNITED STATES DISTRICT COURT LE g
DISTRICT OF CONNECTICUT mm MAR H8 P I2:
UNITED STATES OF AMERICA ;
v. : N0. 3:03CR229(SRU)
FAUSTINO FLEURY : MARCH 8, 2005
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MOTION TO CONTINUE CHANGE OF PLEA l
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The Defendant, acting herein by his undersigned counsel, hereby moves the Court to i
continue the date for the Change of Plea hearing in this matter for approximately three weeks
beyond March 15, 2005 at 11:30 a.m. (Said date is currently scheduled for a change of plea N
before United States Magistrate Judge Donna F. Martinez.) {
The reasons for this request are two—fold. First, in the last two weeks, the Government
has made slight revisions to the proposed Plea Agreement which was first sent to predecessor
counsel in early November of 2004. These changes — which are not major, and are believed to R
have been made to address and deal with some of the issues raised in the January 2005 Egg Q
and Earg cases -— do not affect the proposed agreement as to Defendant’s sentencing range
under the now—advisory U. S. Sentencing Guidelines, but are new provisions which must be I
reviewed carefully with the Defendant, who is now incarcerated at Wyatt Detention Facility in I
Rhode Island.
Second, counsel is currently on vacation, returning to his office on Monday, March
15, 2005.
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Case 3:03-cr—00€2?—RNC Document 123 Filed @8/2005 Page 2 of 3
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This is the first such continuance sought by the Defendant. The undersigned spoke l
with counsel for the Government on March 4, 2005, and the Government does not oppose p
this Motion. K
DEFENDANT
FAUSTINO FLEURY 1
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Bycj g
C. Thomas Furniss 1
ctooeze 1
Furniss & Quinn, P.C. 1
248 Hudson St. 1
Hartford CT 06106
(860) 527-2245
Fax: (860) 241-1032
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e—mai1: c.thomas.t`[email protected] R
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/32628/3/60348vl 1
07/26/04—SP”1`! \

Case 3:03-cr—OO€§—RNC Document 123 Filed (<)3f())8/2005 Page 3 of 3
CERTIFICATION OF SERVICE
This is to certify that a copy ofthe foregoing was mailed on this Sm day of
March, 2005 by first class mail to each of the following:
Hon. Donna F. Maitinez
United States Magistrate Judge ‘
450 Main Street
I-Iartford CT 06103
M. Gordon Hall 5
Assistant United States Attorney
157 Church St.
New Haven CT 06510
Faustino Fleury
Donald W. Wyatt Detention Center ;
950 High St.
Central Falls, Rl
C. Thomas Furniss l
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