Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:03-cr-00129-JCH

Document 22

Filed 01/07/2005

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

JANUARY 7, 2005

MOTION FOR PERMISSION TO TRAVEL The defendant, Roger Bennett, respectfully moves this Court for permission to travel outside the District of Connecticut for a brief family visit prior to his sentencing. In this case, Mr. Bennett has been released on his own personal recognizance, has pleaded guilty and has cooperated with the Government under 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. The defendant's wife strongly desires that the defendant accompany her and their three children, ages 13, 11 and 8, to visit Mrs. Bennett's parents. After retirement, Mrs. Bennett's parents relocated to Florida. It has been Mrs. Bennett's practice to visit her mother and father (69 and 73 years of age, respectively) once a year. Mrs. Bennett feels that it is important at this time for Mr. Bennett to accompany her and their children to visit her mother and father. In addition, the defendant will be able to share with Mrs. Bennett the responsibilities of caring for the children while traveling and during the family visit. The proposed family visit is brief and would not interfere with any of the defendant's obligations to the Government to assist in the investigation and prosecution of others. The proposed schedule for the visit is as follows: Leave Connecticut and arrive in Boca Raton, Florida on Friday, January 14, 2005, visit with Mrs. Bennett's parents Saturday, Sunday and Monday (15th ­ 17th), and return from Florida and arrive in Connecticut on Tuesday, January 18th. Should the Court grants this motion, the defendant of course will provide the U.S.

Case 3:03-cr-00129-JCH

Document 22

Filed 01/07/2005

Page 2 of 2

Probation Office (or anyone else the Court directs) the exact details of the proposed family visit and how the defendant can be reached at all times during such visit. 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. 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 CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing was mailed, postage prepaid, this 7 day of January, 2005 to:
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WILLIAM J. NARDINI ASSISTANT UNITED STATES ATTORNEY United States Attorney's Office 157 Church Street New Haven, Connecticut 06510 (203) 773-2108 ________________________________ STEPHEN V. MANNING O'BRIEN, TANSKI & YOUNG, LLP