Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03—cr—00224-PCD Document 117 Filed 10/25/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA, : CASE NO.: 3:03CR224 (PCD)
1’{.,AINTIFF :
V.
CARLOS DELGADO, -
DE FENDANT : OCTOBER 24, 2007
DEFENDANT CARLOS I)ELGADO’S
MOTION T() CONTINUE VIOLATION HEARING
The detendunt, CARLOS DFELGADO, by and through undersigned counsel,
respectfully moves this Court to continue his violation hearing for thirty (30) days to
November 27, 2007 or a convenient date thereafter. Mr. Delgado’s hearing date is currently
scheduled for October 29, 2007. ln support of this motion, defense counsel represents as
follows:
l. On or about March 22, 2007 the defendant was alleged to have violated the
terms of his supervised release in violation of 18 U.S.C. § 3583.

Case 3:03—cr—00224-PCD Document 117 Filed 10/25/2007 Page 2 of 4
2. The petition for action is based largely on the defendant’s arrests on both May
23, 2007 by the Wi.n.dham Police Department and May 24, 2007 by the
Connecticut State Police.
3. The charges for the above—rnentioned incidents are pending in the Danielson
Superior Court at GA. it l l.
4. U·1`lLlt21`Slgt`t€(i counsel spoke to Attorney John Newson, the defendant’s
attorney in the above—refcrenced state matters.
5. Attorney Newson indicated that he has had preliminary discussions with the
states attorney regarding a possible resoiution ofthe defendant’s cases.
6. Attorney Newson indicated that the defendant’s next court date is November
13***.
7. Undersigned counsel has researched the defendant’s options regarding
resolving, his cases in two different jurisdictions.
8. Undersigned counsel needs additional time to advise Mr. Delgato as to these
options.
9. Undersigncd counsel is scheduled to begin trial in State of Connecticut v.
Todd Ruffin in Stantford Superior court on October 31** and will be unable to
visit with Mr. Delgado until after November ltlth.

Case 3:03—cr—00224-PCD Document 117 Filed 10/25/2007 Page 3 of 4
l0. Undersigned counsel has spoken to Assistant United States Attorney Eric
Glover regmxling this motion. and he does not object to this request.
This is CA..l{.l..,OS `l)`lELGADO’S second motion for it continuance of his violation
hearing.
WHEREFORIE, the defendant CARLOS DELGADO respectfully requests tliat his
motion For at continuance ol' his hearing he grunted.
RQESPECTFULLY SUBMITTED,
THE DEPENBANT, _ _ i... i.tt..
CAKIZUS DEL(}A_Dj;)_W is ...t A 4..4..»l - -4-- S /I//,
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Audrey A. l?elsg3,.,¢E§§]:mM__W_mm_,M_ nsii ...s -» ---»4···ii
l<.oft`sl 1200 St1h11f1¤—€iT._S?§Y€€t
Suite 20lB ```S ‘’‘‘“ M"`-
Stamford, CT 06905
Tel.: 203—32’7-1500
Fax; 203-327-7660
Federal Bar No.: et2089l
E-mail: [email protected]

Case 3:03-cr-00224-PCD Document 117 Filed 10/25/2007 Page 4 of 4
C.l€R’[‘§IFICATION
THIS IS TO CERTIIFY that on the 24th day of October, 2007 a copy ofthe foregoing
was tiled electronically [anti servcti by mail on anyone unable to accept electronic tiling}.
Notice of this iiiizig will be sent hy e·maii to ali parties by operation ofthe Court’s electronic
tiling system. Parties may access this tiling through the Court’s system.
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