Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00198-RNC

Document 1001

Filed 09/08/2005

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

--------------------------------------------------------x UNITED STATES OF AMERICA, Plaintiff VS. CRIMINAL MATTER NO. 3:03CR-198 (RNC)

ANTONIO (RAMON) MARRERO, Defendant --------------------------------------------------------x

September 5, 2005

MOTION OF DEFENDANT ANTONIO (RAMON) MARRERO TO CONTINUE SENTENCING HEARING

Defendant Antonio (Ramon) Marrero, in the above captioned criminal matter, through counsel, respectfully moves the Court hereby to continue the date for the sentencing in the defendant's case from the currently assigned date of Friday, September 23, 2005, until October 19, 2005, or a date thereafter convenient to the Court. In support of this motion, the defendant provides as follows: 1. Antonio (Ramon) Marrero is Spanish-speaking and counsel for defendant has

forwarded Mr. Marrero's Presentence Report to his interpreter for translation. While the court-approved interpreter has promised to translate the Report as quickly as possible, the Report exceeds 12 pages and is full of content, much of which is legal in nature. After the Spanish version of the Report is completed, counsel needs to send the Report to Mr. Marrero

Case 3:03-cr-00198-RNC

Document 1001

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for his review, comments, and objections, if any. At the time, counsel would be in a position to share those comments and objections with the United States Probation Office. 2. The brief additional time requested will not unduly delay the progress of the

defendant's case and will not prejudice the government or create an unfair advantage in favor of the defendant at this important stage of his proceedings. At the same time, the additional time requested for the purpose of providing defendant with and allowing him to comment upon a Report that is in his native language will go a long way to protect his rights in this federal criminal case. 3. For all of the foregoing reasons, defendant moves that his motion be granted

and the date for his sentencing continued until October 19, 2005, or a date thereafter convenient for the Court. Defendant also moves that the dates for comments on and

objections to the Report, the second disclosure, and any sentencing memoranda to be filed by the parties in this case all be extended as well. 4. Finally, the additional time requested will more easily allow defendant to

meet with the government between now and the date of sentencing for his debriefing in pursuit of safety valve treatment under the federal sentencing guidelines. 5. Undersigned counsel for defendant provides that he has contacted the office

of the United States Attorney for the government's position on this motion, but counsel for the government handling this matter was away from the office until the week of September 6, 2005. 6. This is defendant's third motion to continue the sentencing hearing in this

case. Any interest in the general public in a sentencing hearing earlier than the date requested by the defendant is outweighed by the interest of the defendant in the continuance requested.

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Case 3:03-cr-00198-RNC

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WHEREFORE, in consideration of all of the foregoing, the defendant respectfully moves that this motion be granted.

DEFENDANT, ANTONIO MARRERO

By: _______________________________ John T. Walkley 450 Monroe Turnpike, Suite 101 Monroe, Connecticut 06468 Telephone (203) 261-1911 Facsimile (203) 268-1433 Fed. Bar No. ct04341 [email protected]

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Case 3:03-cr-00198-RNC

Document 1001

Filed 09/08/2005

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CERTIFICATION It is certified hereby that a copy of the foregoing was dispatched via first class mail, postage prepaid, this 5th day of September, 2005, to:

Gordon Hall, Esq. Asst. United States Attorney P.O. Box 1824 New Haven, Connecticut 06508-1824

____________________________ John T. Walkley

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