Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:03—cr—00129-JCH Document 37 Filed 08/29/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA :
: CASE NO. 3:03CRI29(JCH)
V. Z
ROGER BENNETT : AUGUST 29, 2005
MOTION TO FILE SENTENCING MOTION AND MEMORANDUM OUT OF TIME
The defendant, Roger Bennett, respectfully requests permission for the late filing of: (1) his
motion for downward departure; and (2) his Sentencing Memorandum. The delay in completing
these documents was occasioned by counseI’s family medical circumstances. The undersigned
has spoken to AUSA Nardini with respect to this motion, and the Government does not object to
the filing out of time.
Respectfully submitted,
THE DEFENDANT
ROGER BENNETT
O’BR1EN, TANS OUNG, LLP
CityP1ace II
185 Asylum Street
Hartford, Connecticut 06103
(860) 525-2700
SVU]§G)0{j{l.3W.COm
FEDERAL BAR NUMBER ct07224

Case 3:03—cr—00129-JCH Document 37 Filed 08/29/2005 Page 2 of 2
CERTIFICATE OF SERVICE
This is to certify that a copy of the within and foregoing was mailed, postage prepaid, this
29"' day of August, 2005, to:
William J . Nardini
Assistant United States Attorney
United States Attorney's Office
157 Church Street
New Haven, Cormecticut 06510
(203) 773-2108
Mr. Raymond Lopez
United States Probation Officer
United States Probation Office
915 Lafayette Boulevard, Room 200
Bridgeport, CT 06604
[1 A, .. ll
Stephen V. Ma n`
O’BRIEN, T - . -. YOUNG, LLP
2