Free Motion to Continue - District Court of Connecticut - Connecticut

i ,_ ' C se 3:03-cr-00182-SRU Document 119 Filed O1/O3/2005 Page 1 of 2 Mi
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i UNITED STATES DISTRJFIm¤OE&') . I
DISTRICT OF CONNECTICUT
ZUHSJAN *3 FD 2:03
i UNITED STATES or AMERICA, ; mtg lNBJMl.RHJKZGL@&‘CR 182 (SRU)
I VS- c ;.-RIUGEPURT, CONS- U
i ALBERT LaTOUCHE ; JANUARY 3, 2005
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i MOTION FOR EXTENSION OF TIME RE: SENTENCING I I
i The defendant, Albert LaTouche, hereby moves this Honorable Court to continue
sentencing in the above referenced case to March 2, 2005. In support of this motion the E “
j defendant asserts the following:
1. On October 12, 2004 the defendant was convicted by jury of 9 counts of Mail Fraud
in violation of Title 18 Section 1341.
2. The defendant’s sentencing is scheduled for January 25, 2005 at 2:00 p.m..
3. The co-defendant Salvatore Carte1li’s sentencing is scheduled for March 4, 2005.
4. Defense counsel is currently on trial in New Britain Superior Court before the
Honorable Joseph M. Shortall in the case of State vs. Casmir Zubrowski. It is anticipated
that the murder trial will last through the first week of February, 2005.
5. Following the State murder trial, defense counsel will need time to review the PSR
and prepare a sentencing memorandum on the defendant’s behalf
6. The government has been contacted and has no objection to this request.
7. The defendant remains at liberty at this time. He waives his rights to a speedy
sentencing. An executed waiver has previously been provided to the clerk of the court.
WHEREFORE, the defendant moves that this motion for extension of time for
sentencing be granted.
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H if U H -`H U H U H U H H H U H U H U H

I " l C se 3*03-cr-00182-.SRU Document 119 Filed O1/O§L2005 Page 2 of 2 I
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Respectfully submitted, I
The Defendant I
By: I
William H. Paetzold I
I Moriarty & Paetzold, LLC
140 Hebron Avenue, Suite 102 I
I Glastonbury, CT 06033
Tel No: (860)657-1010
I Federal Bar No. ct10074
I J
I CERTIFICATION
THIS IS TO CERTIFY that a copy ofthe foregoing was mailed to the following
counsel and parties of record on this 3rd day of January, 2005:
Calvin Kurimai, Esq. Jonathan J. Einhorn, Esq. I
Asst. U.S. Attorney ` 412 Orange Street
157 Church Street, 23“‘ Floor New Haven, CT 06511
New Haven, CT 06510 _ II
illiam H. Paetzold