Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:03-cr-00129-JCH

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Filed 07/14/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. ROGER BENNETT : : : : : : : CASE NO. 3:03CR129 (JCH)

JULY 14, 2006

MOTION FOR PERMISSION TO TRAVEL The defendant, Roger Bennett, who is currently on probation, respectfully moves this Court for permission to travel outside the District of Connecticut to Magog, Canada for the purpose of attending with his wife, Barbara Bennett, a theory workshop. The workshop is July 14-20 in Magog, Canada, approximately 15 minutes over the Vermont border. The workshop is being held at Manoir Des Sables in Magog, Canada. The facilitators of this workshop, Drs. Stuart Alpert and Naomi Lubin-Alpert, are the originators of Body-Centered Gestalt Therapy. Dr. Alpert is Mr. Bennett's primary therapist who highly recommended this workshop for Mr. Bennett. A copy of information related to the Workshop is attached as Exhibit A. As the Court is aware, Mr. Bennett sought the benefit of therapy after his offense conduct and well before the Court imposed sentence. Mr. Bennett had benefited from therapy and continues to benefit from therapy. Further, one of the conditions of the sentence of probation that the Court imposed is that Mr. Bennett is required to continue with his therapy (Condition 1: The defendant shall participate in a mental health program, as directed by the probation officer.). It is respectfully submitted that this therapy is directly in furtherance of this condition of probation. The undersigned respectfully represents that he has spoken to US Probation Officer Jennifer Amato, who indicated that, due to his probationary status, there is a requirement that

Case 3:03-cr-00129-JCH

Document 43

Filed 07/14/2006

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Mr. Bennett receive the permission of the Canadian Government to enter Canada. Ms. Amato stated that the Probation Office has no objection to the proposed trip as long as (1) this Court approves the travel and (2) that the Canadian Government grants him authority to enter the country for this trip. Mr. Bennett and Mrs. Bennett have contacted the Canadian consulate and are taking steps necessary for to present the required information and documents to the Canadian officials to obtain permission for Mr. Bennett to enter Canada. By this motion, Mr. Bennett respectfully seeks an order of this Court granting Mr. Bennett permission to enter Canada and remain in Canada for the period of July 14-20 for the purpose of this therapy workshop, subject to being granted permission by the Canadian officials to enter Canada for this purpose. Should the Court grants this motion, the defendant will provide the U.S. Probation Office (or anyone else the Court directs) the exact details of the travel and how the defendant can be reached at all times during the therapy workshop. Pursuant to Rule 7(b) (3), D. Conn. L. Civ. R., the undersigned counsel states that AUSA Nardini has represented that the Government has no objection to the granting of this motion.1 Respectfully submitted, THE DEFENDANT ROGER BENNETT STEPHEN V. MANNING O'BRIEN, TANSKI & YOUNG, LLP CityPlace II 185 Asylum Street Hartford, Connecticut 06103 (860) 525-2700 Federal Bar Number ct07224

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The defendant respectfully submits with this motion a proposed order page that follows this page.

Case 3:03-cr-00129-JCH

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ORDER Dated: July 14, 2006 Having considered the foregoing motion, the position of the US Attorney's Office and the US Probation Office, the Court herby GRANTS/DENIES Roger Bennett permission to enter Canada and remain in Canada for the period of July 14-20 for the purpose of attending a therapy workshop at Manoir Des Sables in Magog, Canada, subject to being granted permission by the Canadian officials to enter Canada for this purpose. IT IS SO ORDERED.

_____________________________________ JANET C. HALL UNITED STATES DISTRICT COURT JUDGE

Case 3:03-cr-00129-JCH

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing was mailed, postage prepaid, this 14TH day of April 2006 to:

WILLIAM J. NARDINI ASSISTANT UNITED STATES ATTORNEY United States Attorney's Office 157 Church Street New Haven, Connecticut 06510 (203) 773-2108 JENNIFER AMATO UNITED STATES PROBATION OFFICER United States Probation Office 450 main Street Hartford, CT 06103 (860) 240-3661 ________________________________ STEPHEN V. MANNING O'BRIEN, TANSKI & YOUNG, LLP