Free Order on Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00178-RNC Document 77 Filed 08/19/2008 Page1 of4
Case 3:03-cr—00178-RNC Document 76 Filed 08/15/2008 Page 1 of 4
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é UNITED STATES DISTRICT COURT
; DISTRICT OF CONNECTICUT
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é UNITED STATES OF AMERICA, : CASE NO.: 3:03CRl78 (RNC)
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N . CHAUNCEY MOORE, :
L5 DEFENDANT : August 15, 2008
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ij DEFENDANT CHAUNCEY MOORE’S
O MOTION TO CONTINUE SENTENCING
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Q The defendant, CHAUNCEY MOORE, by and through undersigned counsel,
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E respectfully moves this Court to continue his sentencing which is currently scheduled for
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§ August 25, 2008 to September 29, 2008 or a date thereafter that is convenient to the
.§ Court and Counsel. ln support of this motion, defense counsel represents as follows:
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&g_ 1. On or about March 13, 2007, the defendant pled guilty to an indictment
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Q Q Q charging him with Unlawful Possession of a Firearm in violation of 18
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_: — U.S.C. §922(g). Sentencing is currently scheduled for August 25, 2008.
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Case 3:03-cr-00178-RNC Document 77 Filed 08/19/2008 Page 2 of 4
Case 3:03-cr-00178-RNC Document 76 Filed 08/15/2008 Page 2 of 4
point of law he believed was necessary and appropriate in furtherance of a
fair and just sentence.
2. The undersigned counsel needs additional time to meet with the defendant
and to investigate relevant sentencing issues.
3. The undersigned believes that the interests of justice would be fuithered
by allowing the defendant to continue his sentencing until September 29,
2008.
4. The undersigned has spoken to Assistant United States Attorney Paul
Murphy regarding the defendant’s motion, and the government does not
object to the undersigned’s request.
5. This is CHAUNCEY MOORE’s second motion for a continuance of his
sentencing date.
WHEREFORE, the defendant CHAUNCEY MOORE respectfully requests that
his motion for a continuance of sentencing be granted.

Case 3:03-cr-00178-BNC Document 77 Filed 08/19/2008 Page 3 of 4
Case 3:03-cr—00178—RNC Document 76 Filed 08/15/2008 Page 3 of 4
RESPECTFULLY SUBMITTED,
THE DEFENDANT,
CHAUNCEY MOORE
BY
Bruce D. Koftisky, Esq.
Koffsky & Felsen, LLC
1200 Summer Street
Suite 20lB
Stamford, CT 06905
Tel.: 203-327-1500
Fax: 203—327—7660
Federal Bar No.; ct03772

Case 3:03-cr-00178-RNC Document 77 Filed 08/19/2008 Page 4 of 4
Case 3:03-cr-00178-RNC Document 76 Filed 08/15/2008 Page 4 of 4
CERTIFICATION
THIS IS TO CERTIFY that on August 15, 2008 a copy ofthe foregoing
was tiled electronically [and served by mail on anyone unable to accept electronic tiling].
Notice of this tiling will be sent by e-mail to all parties by operation ofthe Court’s
electronic tiling system. Parties may access this tiling through the Court’s system.
Bruce D. Koffsky