Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-or-00198-RNC Document 880 Filed 03/30/2005 Page 1 of 3
UNFFED STATES DiSTRlCT COURT
DISTRJCT OF CONNECTICUT
UNITED STATES OF AMERECA : CASE NO. 3:03 CRt98 (RNC)
v. {
FEFQIX/IiN AOUii\lO, a/kia "Cerlos" MARCH 29, 2005
MOTiON T0 CONTINUE SENTENCING
The defendant, FERIVIIN AQUINO, hereby, moves to continue sentencing for a
period of approximately three weeks from Aprii 4 2005 to a date at the end of April 2005
or such other date as the Court deems appropriate. In support of this motion, counsei
states:
i. On or about November 12, 2004 defendant Ferrnin Aquino pled
guilty to Count One ofthe indictment.
2. Sentencing is presently scheduied for April 4, 2005 but the interests of
justice will best be served by a continuance of the sentence date.
3. Sentencing issues are being investigated by the undersigned
counsei and additionai time is required to prepare and present ali relevant issues
to the Court. In particuiar, defense counsel requests additional time to prepare a
Sentencing i\/Iemorandum. Counsei’s work and travel schedule iast week and this week
has prevented him from completing the Sentencing Memorandum.
4. Mr. Aquino is detained and by this motion waives his right to a
speedy sentencing.
Hrunlvw
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Case 3:03-cr-00198-RNC Document 880 Filed 03/30/2005 Page 2 of 3
5. This is the defendants second request to continue sentencing.
8. The office of the United States Attorney has been consulted
regarding this motion. Assistant United States Attorney Gordon Halt has no
objection to the continuance ofthe sentence to a date in late April 2005.
WHEREFOREE, defendant respectfully requests that the Court continue
the defendants sentencing to a date at the end of April 2005 or such other date
as the Court deems appropriate.
THE DEFENDANT
FERl\i1lN§.QLl|N
By L ·> W
Dan E. t.aBeIIe of
HALLORAN & SAGE LLP
Fed. Bar #ct 01984 `
315 Post Road West
Westport, CT 08880
(203) 22?—2855
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Case 3:03-cr-00198-RNC Document 880 Filed 03/30/2005 Page 3 of 3
CERTiFiCATION
This is to certify that on this 29* day of March, 2005, a copy ofthe
foregoing Motion to Continue Sentencing was mailed, first class postage pre-
paid, to the following counsel of record:
H. Gordon Hall, Esq.
United States Attorneys Othce
157 Church Street, 23“° Floor
New Haven, CT 06510
<’;g@ `
—. ·
Dan E. l.aBe|ie
842205*1 DOC
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