Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr—00152-PCD Document 76 Filed 03/16/2005 Page 1 of 3
UNITED STATES DISTRICT COURT =
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : CRIM. NO.: 3:O3CRl52 (PCD) `
VS. g
MICHAEL MAZZARIELLO : MARCH 16, 2005 3
CONSENT MOTION TO CONTINUE SENTENCING ·
Defendant Michael Mazzariello hereby moves to continue his
sentencing, currently scheduled for March 22, 2005, tc April 7, i
2005 or an alternative date convenient to the Court. In support t
thereof, defendant states as follows:
1. Sentencing in this matter is currently scheduled for Q
March 22, 2005, at 9:00 a.m. é
2. Defendant has received the initial Pre—Sentence Report. g
The principal area of disagreement between the parties concerns the g
amount of financial loss attributable to defendant, and how that E
figure should be calculated. é
3. In an effort to reach agreement, defendant met with the E
government to set forth his version of the events underlying this E
prosecution. Notwithstanding their efforts, the parties have not E
been able to reach agreement on the appropriate loss figure. i
3. Counsel is preparing a submission for the Court and the é
probation office regarding his version of the loss calculation, as Q
well as an analysis of the Supreme Court's ruling in the E
Booker/Fanfan case and the Second Circuit's decisions interpreting g
and offering guidance on how to apply that decision. A short g

Case 3:03-cr—00152-PCD Document 76 Filed 03/16/2005 Page 2 of 3
continuance of the sentencing date is requested so that defendant‘s _
sentencing presentation may be completed, and submitted to all
parties sufficiently in advance cf the sentencing date. K
4. Co-defendant Robert Keller, through his counsel Hubert J. A 7
Santos, Esq., joins in this request for continuance.
4. Assistant United States Attorney Anastasia Enos, Esq.,
attorney for the government in this matter, does not object to the .
granting of this motion.
WHEREFORE, defendant requests that his sentencing be continued
to April 7, 2005 or a date thereafter convenient for the Court.
THE DEFENDANT, -
MICHAEL MAZZARIELLO _
Da i T. Grudber , ct01l86 Q
JACOBS, GRUDBERG, BELT & DOW, P.C. Q
350 Orange St. j
p.o. Box 606 i
New Haven, CT 06503 Q
phone:(203) 772-3100 E
fax: (203) 772-l69l g
email: [email protected] Q
2

Case 3:03-cr-00152-PCD Document 76 Filed 03/16/2005 Page 3 of 3
CERTIFICATION
I hereby certify that a copy of the foregoing was faxed and/or 2
mailed first class, postage prepaid on March 16, 2005 to: i
Anastasia Enos, Esq. E
Assistant United States Attorney E
450 Main sr. g
Hartford, CT 06103 g
Hubert J. Santos, Esq. é
Santos & Seeley, P.C. Q
51 Russ St. Q
Hartford, CT 06106 E
Jacqueline Carroll l
U.S. Probation Officer g
157 Church St. — 22nd Floor §
New Haven, CT 06510 j
QQ T4 Q Q
David T. Gru erg E