Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00188-CFD

Document 129

Filed 05/08/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA vs. MICHAEL SPERO

: 3:03CR188 (CFD) : May 8, 2006 :

MOTION FOR CONTINUANCE OF SENTENCING HEARING Defendant, Michael Spero, by and through his attorney, hereby moves this Honorable Court to continue the sentencing hearing set for May 24, 2006 at 10A.M. for the reasons set forth below: (1) On Defendant's Motion, the sentencing set for March 24, 2006 was continued until May 24, 2006 at 10A.M. (2) As part of the motion for that continuance, Counsel for the Defendant advised the Court that she was in the process of locating and interviewing an expert in the evaluation of sex offenders to evaluate Mr. Spero before sentencing. Counsel for Mr. Spero has located and interviewed several experts and has conferred with Mr. Spero on the selection of an expert in the evaluation of sex offenders. During the week of May 1, 2006, Mr. Spero selected an expert. Counsel for Mr. Spero wrote to David Winn, Warden, FMC Devens today to request that Mr. Spero's expert in the evaluation of sex offenders be allowed admission to FMC Devens for the purpose of interviewing Mr. Spero. The date of availability for the expert was May 22, 2006. We are awaiting approval from FMC Devens and I have been advised that the approval process may take two weeks or more.

Case 3:03-cr-00188-CFD

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Filed 05/08/2006

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(3) Counsel for Mr. Spero believes that a continuance of 60 days from May 24, 2006 is required to permit the evaluation of Mr. Spero, the preparation of a report and the filing of appropriate sentencing submissions based on that report. (4) On May 8, 2006, the undersigned attempted to consulted John A. Danaher, AUSA for his concurrence or non-concurrence in the request for a 60 day continuance of the sentencing hearing and Mr. Danaher was not available. WHEREFORE, Defendant moves this Honorable Court to continue the sentencing for 60 days from May 24, 2006. Dated: May 8, 2006 Respectfully submitted, /s/Cheryl J. Sturm Cheryl J. Sturm Attorney at Law 387 Ring Road Chadds Ford, Pa. 19317 484-771-2000 [email protected] Federal Bar No. CT12801

Case 3:03-cr-00188-CFD

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CERTIFICATE OF SERVICE Cheryl J. Sturm, Attorney at Law, hereby certifies that on the 8th day of May, 2006 she caused a copy of the within Motion for Continuance of Sentencing Hearing to be served upon opposing counsel and all interest parties by United States Mail, first class postage pre-paid and addressed as follows: Richard S. Cramer Attorney at Law 449 Silas Deane Highway Wethersfield, CT 06109 John A. Danaher, III Assistant U.S. Attorney 450 Main Street Hartford, CT 06103

/s/Cheryl J. Sturm Cheryl J. Sturm Attorney at Law