Free Motion for Departure - District Court of Connecticut - Connecticut

Case 3:03-cr-00129-JCH

Document 34

Filed 08/26/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. ROGER BENNETT

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Case No. 3:03-CR-129 (JCH)

August 26, 2005

GOVERNMENT'S MOTION FOR DOWNWARD DEPARTURE Pursuant to Section 5K1.1 of the Sentencing Guidelines and Title 18, United States Code, Section 3553(e), the United States moves the Court to depart downward from the defendant's guidelines range, because the defendant has provided substantial assistance in the investigation or prosecution of other persons who have committed offenses. The grounds that support the granting of this motion are set forth in the Government's Memorandum in Support of Motion for Downward Departure. Respectfully submitted, JOHN H. DURHAM ACTING UNITED STATES ATTORNEY

STEPHEN B. REYNOLDS ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT19105 for WILLIAM J. NARDINI ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT16012 157 CHURCH STREET, 23RD FLOOR NEW HAVEN, CT 06510 (203) 821-3748 fax (203) 773-5377 [email protected]

Case 3:03-cr-00129-JCH

Document 34

Filed 08/26/2005

Page 2 of 2

CERTIFICATION OF SERVICE This is to certify that a copy of the within and foregoing has been sent by e-mail this 26th day of August 2005 to: Stephen V. Manning, Esq. O'Brien, Tanski & Young, LLP CityPlace II - 185 Asylum Street Hartford, CT 06103-3402 [email protected]

_____________________________________ Stephen B. Reynolds, Assistant U.S. Attorney, for William J. Nardini, Assistant U.S. Attorney

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