Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00198-RNC Document 785 Filed 1 1/29/2004 Page 1 of 3 I
UNITED STATES DISTRICT COURTF E L g
DISTRICT OF CONNECTICUT
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UNITED STATES OF AMERICA _ _ __
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v. No. 3:03 Cr 198 (RNC)
DONNA JOHNSON
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MOTION TO CONTINUE SENTENCING I
The Defendant in the above-entitled action, by and through counsel, respectfully
moves that the Defendant’s sentencing, presently scheduled for December 10, 2004, be i
continued to a date in February, 2004 that is convenient for the Court.
Qkground
The Defendant underwent hip-replacement surgery earlier this year. She suffered
physical setbacks in her rehabilitation from that injury, which had impeded her progress.
These physical setbacks, including falling in a hospital, had required her doctors to i
increase her pain medication significantly, which limited her ability to participate in any
meaningful activity. She was unable to walk, or to sit in an upright position. She had a l
series of medical appointments scheduled concerning these issues, and those relating to a
severe and debilitating back condition. That is the reason the case had been previously
continued.
On October ll, 2004, the defendant underwent exploratory back surgery at E
Temple Medical Center, in New Haven. That exploratory surgery confirmed that she
must immediately undergo back surgery, and that her condition has worsened, something
her doctors had previously believed. As a result of her back condition, compounded by a
November 4 knee procedure, which caused swelling and internal bleeding, she continues
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I Case 3:03-cr—00198—RNC Document 785 Filed 11/29/2004 Page 2 of 3
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I to lack the flexibility to accomplish routing tasks, such as dressing, or standing for that
matter. The back-fusion surgery is scheduled for the first week of December.
The Defendant also suffers from other significant medical impairments, which
continue to impact her, and for which she continues to receive medical attention. The
defendant continues to require a high dose of Fentanyl (pain killer), neuroton (for nerve
rehabilitation), and other medications to treat muscle spasms, severe migraine headaches,
and other physical problems.
A continuance is necessary in order to allow the defendant to undergo
I back surgery and have some period for recovery. For this reason, it is in the interests of
justice to continue this case for sentencing, `
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Assistant United States Attorney Gordon Hall has consented to this request. /
Respectfully submitted,
Robert Y. Altchiler
Attorney for Defendant
Donna Johnson
191 Post Road West
Westport, CT 06880
Tel.: 203.545.0412
Fax: 8'/7.495.5970
ALTCIJLAVI/{az)/\OL.CO`I\/I J
Dated: November 24, 2004, 2004, r
Westport, CT
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i Case 3:03-cr—00198—RNC Document 785 Filed 11/29/2004 Page 3 of 3 Q
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CERTIFICATION ]
S THIS IS TO CERTIFY that a copy of the foregoing was sent via electronic mail to
S Assistant United States Attorney Gordon Hall, at Gordon.hallgoDusdojgov, on this first
day of November 24, 2004.
Robert Y. Altchiler I
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