Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00188-CFD

Document 126

Filed 03/14/2006

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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) : March 14, 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 March 24, 2006 for the reasons set forth below: (1) Mr. Spero, his counsel and Joseph Montesi, USPO have agreed that the Presentence Investigation Report would be updated by a three way telephone conference, with Mr. Spero participating from FMC Devens. The conference has not yet occurred. (2) Counsel for the Defendant is in the process of locating and interviewing an expert in the evaluation of sex offenders to evaluate Mr. Spero before sentencing. Counsel believes that an additional thirty days will be required to have the evaluation performed. (3) The undersigned has consulted John A. Danaher, AUSA and Mr. Danaher does not oppose the request to continue the sentencing hearing for a period of 60 days. (4) The parties respectfully propose to the Court that the sentencing be continued to a date during the week of May 22, 2006. The parties further propose that Defendant's

Case 3:03-cr-00188-CFD

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Sentencing Memorandum would be due two weeks before the date of sentencing and that the Government's Memorandum would be due one week before that date. WHEREFORE, Defendant moves this Honorable Court to continue the sentencing date from March 24, 2006 to a date during the week of May 22, 2006. Dated: March 14, 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 14th day of March, 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