Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:O3—cr—O0129-JCH Document 26 Filed O3/O4/2005 Page 1 of 1 A
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA :
: CASE NO. 3:03CR129(JCH)
v.
ROGER BENNETT MARCH 4, 2005
MOTION FOR PERMISSION TO TRAVEL
The defendant, Roger Bennett, respectfully moves this Court for permission to travel
outside the District of Connecticut on a brief business trip prior to his sentencing. In this case,
Mr. Bennett has been released on his own personal recognizance, has pleaded guilty and has
A cooperated with the Government Lmder a cooperation agreement. It is respectfully submitted that
Mr. Bennett does not pose a risk of flight and that the Court had every reason to believe that Mr.
Bennett will appear in Court as required in this matter.
One of the defendant’s corporate business clients is located in Atlanta, Georgia, and Mr.
Bennett is responsible for providing the company’s year-end tax services. To perform those tax
services, Mr. Bennett’s presence is required for a brief period at the Company’s location in
Atlanta. The proposed business trip is short and would not interfere with any of the defendant’s
1 obligations to the Government to assist in the investigation and prosecution of others. The
proposed schedule for the trip is as follows: Leave Connecticut and arrive in Atlanta, Georgia on
Thursday, March 10, 2005, assist the client in their business needs, and return to Connecticut the
following morning on Friday, March ll, 2005. Should the Court grants this motion, the
defendant of course will provide Ms. Kattya Lopez at the U.S. Probation Office (or anyone else
the Court directs) the exact details of the proposed business trip and how the defendant can be
l reached at all times during such trip.