Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00152-PCD

Document 68

Filed 01/19/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. MICHAEL MAZZARIELLO : JANUARY 19, 2005 : CRIM. NO.: 3:03CR152 (PCD)

CONSENT MOTION TO CONTINUE SENTENCING Defendant Michael Mazzariello hereby moves to continue his sentencing, currently scheduled for January 25, 2005, to February 28, 2005 or an alternative date convenient to the Court. support thereof, defendant states as follows: 1. Sentencing in this matter is currently scheduled for In

January 25, 2005, at 9:00 a.m. 2. Defendant received the Pre-Sentence Report initial Defendant needs additional time to

disclosure on January 7, 2005.

review the report and respond to the probation office regarding disputed issues, especially those relating to loss calculation. 3. In addition, counsel needs additional time to analyze the

Supreme Court's ruling in the Booker/Fanfan case, to determine its implications for this matter. 4. Assistant United States Attorney Anastasia Enos, Esq.,

attorney for the government in this matter, does not object to the granting of this motion.

Case 3:03-cr-00152-PCD

Document 68

Filed 01/19/2005

Page 2 of 2

WHEREFORE, defendant requests that his sentencing be continued to February 28, 2005 or a date thereafter convenient for the Court. THE DEFENDANT, MICHAEL MAZZARIELLO

By__________________________________ David T. Grudberg, ct01186 JACOBS, GRUDBERG, BELT & DOW, P.C. 350 Orange St. P.O. Box 606 New Haven, CT 06503 phone:(203) 772-3100 fax: (203) 772-1691 email: [email protected] CERTIFICATION I hereby certify that a copy of the foregoing was mailed first class, postage prepaid on January 19, 2005 to: Anastasia Enos, Esq. Assistant United States Attorney 450 Main St. Hartford, CT 06103 Hubert J. Santos, Esq. Santos & Seeley, P.C. 51 Russ St. Hartford, CT 06106

_____________________________ David T. Grudberg

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