Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:O3—cr—O0224-PCD Document 114 Filed O9/26/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
I UNITED STATES OF AMERICA, : CASE NO.: 3:03CR224 (PCD)
PLAINTIFF :
V.
CARLOS DELGADO,
DEFENDANT : SEPTEMBER 26, 2007
DEFENDANT CARLOS DELGAI)O’S
MOTION TO CONTINUE VIOLATION HEARING
The defendant, CARLOS DELGADO, by and through undersigned counsel,
respectfully moves this Court to continue his violation hearing for sixty (60) days to
November 27, 2007 or a convenient date thereafter. Mr. Delgado’s hearing date is currently
scheduled for September 27, 2007. In support of this motion, defense counsel represents as
follows:
I. 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:O3—cr—O0224-PCD Document 1 14 Filed O9/26/2007 Page 2 of 4
2. The petition for action is based largely on the clefendanfs arrests on both May
23, 2007 by the Windham 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 G.A. # ll.
4. Unciersigned counsel requests a sixty (60) day extension oftime within which
to hold a violation hearing so that undersigned counsel can consult with
Attorney John Newson, who is handling Mr. Delgado’s state rnatters.
5. Undersigned counsel has spoken to Assistant United States Attorney Eric
Glover regarding this motion, and he does not object to this request.
This is CARLOS DELGADO’S tirst motion for a continuance of his violation
hearing.
WHEREFORE, the defendant CARLOS DELGADO respectfully requests that his
inotion for a continuance of his hearing be granted.
RESPECTFULLY SUBMITTED,
THE DEFENDANT,
CARLOS DELGADO

Case 3:03-cr-00224-PCD Document 114 Filed O9/26/2007 Page 3 of 4
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Case 3:03-cr-00224-PCD Document 114 Filed O9/26/2007 Page 4 of 4
CERTIFICATION
THIS ES TO CERTIFY that on the 26th day of September, 2007 a copy of the
foregoing was tiled electronically [and served by mail on anyone unable to accept electronic
tiling]. Notice of this tiling will be sent by e—mail to all parties by operation of the Court’s
electronic tiling system. Parties may access this tiling througntlm Court’s system.
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