Free Motion to Continue - District Court of Connecticut - Connecticut

' ° ase 3:03-cr—OO198—gFlNC Document 797 Filed 12/I O/2004 Paget of 3
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UNITED STATES DIST? .
FOR THE
I DISTRICT OF CONNECTICUT
ZUGU DEC I0 A l0= 55
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UNITED STATES OF AMERICA, I
Plaintiff
A - CRIMINAL MATTER
g VS. NO. 3:03CR-198 (RNC)
ANTONIO MARRERO, December 8, 2004
Defendant
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D MOTION TO CONTINUE JURY SELECTION
Defendant Antonio Marrero, in the above captioned criminal matter, through counsel,
respectfully moves the Court hereby to continue the date for jury selection in this case hom
g the currently assigned date of Tuesday, December I4, 2004, until the Court’s jury selection
D date during the month of February of 2005. In support of this motion, the defendant
provides as follows:
1. On November 17, 2004, defendant appeared before the Court, United States
“ Magistrate Judge Donna Martinez, to change his plea in this case and enter a plea of guilty.
Very close tc the conclusion of the plea proceeding, during that portion of the plea where
defendant allocates as to those facts or events that make him guilty of the crime to which he
is pleading, defendant responded in a way that made it apparent that he could not continue his
plea at that time.
2. Despite efforts by counsel for the defendant and the government on the day of
the guilty plea, it became obvious we would be unable to resurrect the plea at that hearing.
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- I ase 3:03-cr—0019@¢l§iNC Document 797 Filed 12/G 052004 Page 2 of 3
3. Defendant does not want to go to trial in his case and remains resolved to
I enter a plea of guilty and accept the sentence as it has been explained to defendant it would
likely be calculated in his case. }
I- 4. Since the time of the change of plea proceeding, counsel for defendant and the l
government have discussed on more than one occasion how the plea could be taken to l
accomplish what has been intended in defendant’s case. Despite these further eiforts to
~ proceed to a guilty plea, the mechanism to get this done has not yet been determined.
5. In tiling this motion, defendant seeks to continue the current jury selection
date Hom December 14, 2004, until the Court’s jury selection calendar during the month of
February- of 2005. In making this motion, it is the intention of both the defendant and the
government to arrange for the defenclant’s change of plea at the earliest available date that
will permit the defendant to understand fully the plea he is entering and accomplish the
mission on which defendant set out on November 14.
6. In filing this motion, defendant asserts that the government has no objection to
the granting of the continuance of jury selection in this case and joins in this request.
WHEREFORE, in consideration of all of the foregoing, the defendant respectfully
moves that this motion be granted.
DEFENDANT, ANTONIO MARRERO
J •. T. Walkley _
` ` 0 Monroe Turnpike, Suite 101
Monroe, Connecticut 06468
Telephone (203) 261-1911
Facsimile (203) 268-1433
Fed. Bar No. ct04341
2

I
ase 3:03-cr—OO1%8—~BNC Document 797 Filed 12ti 052004 Page 3 of 3
QERTIFICATION
It is certified hereby that a copy of the foregoing was dispatched via first class mail,
postage prepaid, and via facsimile this 8th day of December, 2004, to:
Gordon Hall, Esq.
Asst. United States Attorney
P.O. Box 1824
New Haven, Connecticut 06508-1824
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