Free Motion for Order - District Court of Connecticut - Connecticut

Case 3:03-cr-00204-EBB

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Filed 11/30/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. PAMELA KAICHEN : : : : : CASE NO: 3:03cr00204(EBB) 3:03cr00220(EBB)

NOVEMBER 29, 2004

GOVERNMENT'S MOTION FOR ENTRY OF AMENDED RESTITUTION ORDER On or about March 25, 2004, the Government filed a "Motion for Amended Restitution Order" in the above-referenced cases. In that motion, the Government explained that, although the $42,161.98 amount of restitution ordered by the Court was correct, the amount actually seized by law enforcement had been miscounted and was less than previously believed. As a result, the Government sought an amended order of restitution requiring the defendant to pay the balance of the required restitution ­ namely $3,459.81 ­ at the direction of the Probation Office and upon a schedule and at a rate that the defendant could afford. The defendant sought an extension of time in which to respond to the Government's motion so that her counsel could investigate the issue further. After several logistical snags, not attributable to either party, counsel for the defendant had an opportunity to review the money in evidence that was recovered, in person, at the Offices of the Federal Bureau of Investigation in Bridgeport. Following that meeting, on or about October 7, 2004, the defendant filed her "Response to Government's Motion for Amended Restitution Order" indicating that, "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 scheduled and at a rate that the defendant can afford,' Ms. Kaichen has no objection to this request." On or about October 14, 2004, the Court granted, absent objection, the Government's

Case 3:03-cr-00204-EBB

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Filed 11/30/2004

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Motion for an Amended Restitution Order. Pursuant to a request from the Court, the Government hereby submits the attached proposed Amended Restitution Order in duplicate, drafted along the lines set forth in its initial Motion, and respectfully requests entry of the proposed Order by the Court in both cases.

Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

STEPHEN B. REYNOLDS ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. ct19105 UNITED STATES ATTORNEY'S OFFICE 915 LAFAYETTE BOULEVARD BRIDGEPORT, CT 06604 (203)696-3000 (203)579-5575 (fax) [email protected]

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Case 3:03-cr-00204-EBB

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Filed 11/30/2004

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CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was forwarded by mail on Monday, November 29, 2004 to: Tom Belsky, Esq. Assistant Federal Public Defender Federal Public Defender's Office 2 Whitney Avenue, Suite 300 New Haven, CT 06510

STEPHEN B. REYNOLDS ASSISTANT UNITED STATES ATTORNEY