Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00198-RNC

Document 981

Filed 08/10/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, PLAINTIFF V. CARLOS LEBRON, DEFENDANT : : : : : : : CASE NO.: 3:03CR198 (RNC)

AUGUST 9, 2005

DEFENDANT CARLOS LEBRON'S MOTION FOR CONTINUANCE OF SENTENCE

The defendant, CARLOS LEBRON, by and through undersigned counsel, respectfully moves this Court to continue his sentencing date for thirty (30) days until September 12, 2005 at 9:30 a.m. Mr. Lebron's sentencing date is currently scheduled for August 12, 2005. In support of this motion, defense counsel represents as follows: 1. On or about October 2, 2003, the defendant pled guilty to one count of Conspiracy To Distribute Narcotics in violation of 21 U.S.C. §§841 and 846. 2. Since that date, the defendant has been interviewed by the United States Attorney's Office and members of law enforcement for the purposes of assisting in the prosecution of federal crimes. The defendant's assistance

Case 3:03-cr-00198-RNC

Document 981

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has been completed and the undersigned now expects that the government will be filing a motion with the Court pursuant to U.S.S.G. § 5K1.1. The

undersigned additionally will be filing a Memorandum in Aid of Sentencing bringing to the Court's attention matters that the undersigned believes will aid the Court in determining an appropriate sentence in this matter. 3. The undersigned believes that the interests of justice would be furthered by allowing the defendant to continue to assist law enforcement prior to his sentencing. 4. The undersigned has spoken to Assistant United States Attorney H. Gordon Hall regarding the defendant's motion, and the government does not object to the undersigned's request. 5. This is CARLOS LEBRON'S fifth motion for a continuance of his sentencing date.

Case 3:03-cr-00198-RNC

Document 981

Filed 08/10/2005

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WHEREFORE, the defendant CARLOS LEBRON respectfully requests that his motion for a continuance of sentencing be granted.

RESPECTFULLY SUBMITTED, THE DEFENDANT, CARLOS LEBRON

BY______________________________ Bruce D. Koffsky, Esq. Law Offices of Bruce Donald Koffsky 1200 Summer Street Suite 201B Stamford, CT 06905 Tel.: 203-327-1500 Fax: 203-327-7660 Federal Bar No.: ct03772

Case 3:03-cr-00198-RNC

Document 981

Filed 08/10/2005

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CERTIFICATION

THIS IS TO CERTIFY that a copy of the foregoing has been mailed, via Federal Express, this 9th day of August, 2005 to the following: Clerk of the Court United States District Court 450 Main Street Hartford, CT 06103 and has been sent via facsimile and U.S. Mail, postage prepaid, this 9th day of August, 2005 to all counsel and pro se parties of record as follows: AUSA Peter Markle Office of the United States Attorney Connecticut Financial Center 157 Church Street 23rd Floor New Haven, CT 06510 AUSA H. Gordon Hall Office of the United States Attorney Connecticut Financial Center 157 Church Street 23rd Floor New Haven, CT 06510

United States Probation Officer Joseph Montesi United States Probation Office Connecticut Financial Center 157 Church Street New Haven, CT 06510

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Bruce D. Koffsky