Free Motion for Extension of Time - District Court of Connecticut - Connecticut

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I C e 3:03-cr-00198-RNC Document 1091 Fil d 07/24/2006 Pao) glklfilvsf
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Joni RoMAN : JULY 21, 2aI II I
MOTION ron Ewuncsm NT or Tnvm I
Pursuant to Rule 45(b) of the Federal Rul s-of Criminal Proced ·, Defendant
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JOEL ROMAN, hy and through his undersigne counsel, hereby requ Ir an I
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enlargement of time until August 3l, 2006, to file his motion and memo 1 I Idum
regarding re—sentencing issues. He represents in upport of said motionI: I
l) On July ll, 2003, the Defendant was a rested by ConnecticuI s Ite
authorities on narcotics charges; he plead guilty n§October 9, 2003, an as
sentenced to 42 months to serve. I I I
2) Shortly thereafter, he was indicted on he ab0ve—entitled ma » 0 I
3) Undersigned counsel was appointed to represent him in the Ia} case.
4) She was also appointed to represent hi in an ancillary stateI 1 ceeding
in which she tiled a motion to vacate the state sen ence so the DefendanI Iuld be in
federal custody at the time of the federal sentenci
5) The motion to vacate was granted; acc rding to the state couI t ittimus,
“Sentence from 10/9/03 is vacated. I)efendant is r manded into Federal ~ _ Iody..."
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6) On August 6, 2004, the Defendant w· ved indictment, pleatI g ilty to a I
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substitute Information charging possession with ntent to distribute he o _ before the
Honorable Donna F. Martinez. I
7) On December I6, 2004, he was senten ed to a term of 79 moI ty a by the I
Honorable Robert N. Chatigny. I
8) The 79 month term had been adjusted to take into account tI = _7 month `
period spent in state custody on the 42 month sta e sentence for condu I . Ialevant to
the instant federal case. I
9) It was anticipated that the state sente e would be re—impos li run
concurrent to the federal sentence, thus making t e two drug cases, in t, fully I
concurrent. U I
10) lt now appears the Defendant may not have received all of t}I tended
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credit toward his federal sentence, in part becaus · he was still sewing I i Ite court
sentence for violation of a special parole term. I -
ll) Undersigned counsel needs additional imc to research the rI ·· tencing
issues and to discuss the issues with the Defendan . I I
12) The Defendant is currently incarcerat at the Federal Cor gonal
Institution at Coleman, Florida. I I
13) Communication with the Defendant i difficult because of d l Is and
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errors in the mail service to and from FCI-Colem n-; for example, mail · I to the
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Defendant, properly addressed, was inexplicabl forwarded to the Fed = I1
Correctional Institution at Schuykill, Pennsylva ia (where he has neve 1 en) and
then returned to undersigned counsel. 1 I
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14) Pursuant to USDC Local Rule 9(b)(3 , undersigned counselI . ke with
Assistant United States Attorney H. Gordon Hal by telephone on July 1 ( 12006,
to determine whether the government objects to his motion. I I I ,
15) AUSA Hall said he has no objection t - an enlargement of ti 1- ntil
August 31, 2006.
16) This is the Defendant's second motio for extension of time a ile I
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his motion and memorandum regarding re-sente cing issues. I
WHEREFORE, the Defendant respectfully requ sts until August 31, 2 I 1 ito file
his motion and memorandum regarding re—sente cing issues. I 1
DE ENDANT, JOEL R0 N
BY ‘ ¢§|2_:!.(.. I
A G ETP.LEV (
F deral Bar No. ct0004 F
` `s Attorney 1
2 Oak Street I
I4 rtford, CT 06106-80 I ,
( 0) 525—9l19 I
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1 _ CERTIFIC TION 1
THIS IS TO CERTIFY that a copy 0f the foregoing was mailed11 i day, 1
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postage pre-paid, or was hand-delivered to the f n I lowing:
Hon. Robert N. Chatigny
United States District Court i
450 Main Street 1
Hartford, CT 06103 -
H. Gordon Hall
Assistant United States Attorney
157 Church Street — 23d floor
New Haven, CT 06510
Probation Officer Joseph Montessi 1
157 Church Street- 22d floor 1 1
New Haven, CT 06510 1 1 1
Joel Roman 1
Reg. No. 15336-014 .
F Cl-Coleman 1
P.0. Box 1032 1 1
Coleman, FL 33521-1032
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