Free Motion to Continue - District Court of Connecticut - Connecticut

ase 3:03-cr—00198-RNC Document 1008 Filed 09/19/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA, : CASE NO.: 3:03CR198 (RNC)
PLAINTIFF :
CARLOS LEBRON,
DEFENDAN T : SEPTEMBER 15, 2005
DEFENDANT CARLOS LEBRON’S
MOTION FOR CONTINUANCE OF SENTENCING
The defendant, CARLOS LEBRON, by and through undersigned counsel,
‘ respectfully moves this Court to continue his sentencing date for twenty-eight (28) days
until October 7, 2005 at 1:00 p.m. Mr. Lebron’s sentencing date is currently scheduled
for September I2, 2005. In support of this motion, defense counsel represents as follows:
l. On or about October 2, 2003, the defendant pled guilty to one count of
Conspiracy To Distribute Narcotics in violation of 2l U.S.C. §§84l 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

ase 3:03-cr-00198-RNC Document 1008 Filed 09/19/2005 Page 2 of 4
has been completed and the undersigned now expects that the government
will be tiling a motion with the Court pursuant to U.S.S.G. § 5KI.l. 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 fmthered
by allowing the defendant to continue to assist law enforcement prior to
his sentencing.
T 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 sixth motion for a continuance of his
sentencing date.

ase 3:03-cr-00198-RNC Document 1008 Filed 09/19/2005 Page 3 of 4
WHEEFORE, the defendant CARLOS LEBRON respectfully requests that his
motion for a continuance of sentencing be granted.
RESPECTFULLY SUBMITTED,
THE DEFENDANT,
KXCARLOS LEBRON
_\ / 1
BY ..l r
Bruce D. Koffsky, Esq. 1
Law Offices o1°Brnce Donald offsky
:1200 Summer Street `
Suite 201B
Stamford, CT 06905
Tel.: 203-327-1500
Fax: 203-327-7660
Federal Bar N0.: ct03772

ase 3:03-cr-00198-RNC Document 1008 Filed 09/19/2005 Page 4 of 4
CERTIFICATION
THIS IS TO CERTIFY that a copy of the foregoing has been mailed, via U.S.
Mail, postage prepaid, this 15m day of September, 2005 to ali counsel and pro se parties
of record as follows:
AUSA Peter Markle AUSA H. Gordon Hall
Office of the United States Attorney Office of the United States Attorney
Connecticut Financial Center Connecticut Financial Center
157 Church Street 157 Church Street
23rd Floor 23**1 Floor
New Haven, CT 06510 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.` Koffsk