Free Reply/Response Misc - District Court of Connecticut - Connecticut

n I Case 3:03-cr-00220-EBB Document 41 Filed 1 1/29/2004 Page 1 of 2 E
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA :
vs. : CRIMINAL NO. 3:03CR00220(EBB)
PAMELA KAICHEN : November 24, 2004
DEFENDANT’S RESPONSE TO GOVERNMENTS MOTION FOR
AMENDED RESTITUTION ORDER
The Defendant, Pamela Kaichen, respectfully submits this response, in which she poses no
objection to the .government’s motion. for amended restitution order.
On February 2, 2004, the Court sentenced Ms. Kaichen. As part of its sentence, the Court
ordered Ms. Kaichen to pay restitution of $42, 161.98. On March 25, 2004, the government timely
moved for an amended restitution order based, in part, on an inaccurate counting of the money
seized from Ms. Kaichen’s apartment subsequent to her arrest. Ms. Kaichen sought an extension of
time in which to reply to the motion so that her counsel could investigate the situation.
After several administrative snags, non- attributable to either party, coun-sel for Ms. Kaichen
recently had the opportunity to review the evidence in question, and investigate both the accuracy of
_ the claimed loss amount as well as the actual amount seized. Based on this investigation, it appears
that the amount listed in the Court’s judgment, $42,161.98, is the accurate and correct amount of
loss in this case. Thus, there is no need to amend the amount of the restitution order.
Additionally, it appears that the authorities only seized $39,459.8.1 from Ms. Kaichen’s
apartment. Thus, to the extent the government seeks an amended order “requiring the defendant to -
pay the difference between the loss amounts and the monies actually recovered .. upon a schedule
and at a rate that the defendant can afford," Ms. Kaichen has no objection to this request.
Respectfully submitted,
THE DEFENDANT,
PAMELA KAICHEN
THOMAS G. DENNIS
FEDERAL DEFENDER

Case 3:03-cr-00220-EBB Document 41 Filed 11/29/2004 Page 2 of 2
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Dated: November 24, 2004 9
Thomas P. elsky
Asst. Federal Defender
2 Whitney Ave., Suite 300
New Haven, CT 06510
Bar No. ct24770
(203) 498-4200
CERTIFICATION
I HEREBY CERTIFY that a copy of the foregoing has been mailed to Stephen B. Reynolds,
Assistant United States Attorney, United States Courthouse, 915 Lafayette Boulevard, Bridgeport,
CT 06604, on this 24th day of November 2004.
Thomas Belsky E \