Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00178-RNC Document 76 Filed 08/15/2008 Paget of4
UNITEI) STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA, : CASE NO.: 3:03CR1’78 (RNC)
PLAINTIFF :
. CHAUNCEY MOORE,
DEFENDANT : August I5, 2008
DEFENDANT CHAUNCEY MOORE’S
MOTION TO CONTINUE SENTENCING
The defendant, CHAUNCEY MOORE, by and through undersigned counsel,
respectfully moves this Court to continue his sentencing which is currently scheduled for
August 25, 2008 to September 29, 2008 or a date thereafter that is convenient to the
Court and Counsel. In support of this motion, defense counsel represents as follows:
l. On or about i\/larch t3, 2007, the defendant pled guilty to an indictment
charging him with Unlawful Possession of a Firearm in violation of 18
I U.S.C. §922(g). Sentencing is currently scheduled for August 25, 2008.
At the time of his plea, the Court indicated to the defendant that he would
have ample time to research, brief and prepare to argue each and every

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 te 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 defendanfs motion. and the government does not
object to the u.ndersigned’s request.
5. This is CHAUNCEY MOORE’s second niotion for a continuance of his
sentencing date.
WHEREFORE, the defendant CHAUNCEY MOORE respectfully requests that
his niotien for a continuance of sentencing be granted.

Case 3:03-cr-00178-RNC Document 76 Filed 08/15/2008 Page 3 of 4
RESPECTFULLY SUBMITTED,
THE DEFENDANT,
CI-IAUNCEY MOORE
BY
Bruce D. Keffsky, Esq.
KOH`sky & Felsen, LLC
1200 Summer Street
Suite 201B
Stamford, CT 06905
Tel.: 203-327-1500
Fax: 203-327-7660
Federal Ba1·N0.: ct03772

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 ot` the foregoing
was tiled eiectronicaiiy {and served by mail on anyone unable to accept electronic tiling].
Notice of this tiiing wili be sent by e—n1ail to all parties by operation ofthe Court’s
electronic tiling system. Parties may access this tiling through the Court’s system.
Bruce D. Koftisky