Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00152-PCD

Document 65

Filed 01/12/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA Plaintiff V. : : : : : : : : CASE NO. 3:03CR152 (PCD)

ROBERT L. KELLER, JR. Defendant

JANUARY 11, 2005

MOTION TO CONTINUE SENTENCING (NO OBJECTION) The Defendant, Robert Keller, respectfully requests that the sentencing in this matter be continued to March 2, 2005 or a date thereafter. In support thereof, the Defendant states the following: 1. 2. Sentencing is currently scheduled for January 24, 2005. Assistant United States Attorney Anastasia Enos, attorney for the government in

this matter, does not object to the granting of this motion. 3. 4. 5. The co-defendant, Mr. Mazzariello, does not object to the granting of this motion. The pre-sentence report was disclosed to the Defendant on January 7, 2005. The Defendant needs additional time to respond to the loss calculation and other

issues discussed in the pre-sentence report.

THE DEFENDANT, ROBERT L. KELLER, JR.

Case 3:03-cr-00152-PCD

Document 65

Filed 01/12/2005

Page 2 of 2

BY HUBERT J. SANTOS Federal Bar No. ct00069 SANTOS & SEELEY, P.C. 51 Russ Street Hartford, CT 06106 (860) 249-6548

CERTIFICATION THIS IS TO CERTIFY THAT a copy of the foregoing was mailed first class, postage prepaid this 11th day of January, 2005 to: Anastasia Enos, Esq. Assistant United State's Attorney United State's Attorney's Office 450 Main Street Hartford, CT 06106 David T. Grudberg, Esq. Jacobs, Grudberg, Belt & Dow, P.C. 350 Orange Street P.O. Box 606 New Haven, CT 06503

HUBERT J. SANTOS

-2-