Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:03-cr-00129-JCH

Document 17

Filed 11/17/2004

Page 1 of 2

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

NOVEMBER 17, 2004

MOTION FOR PERMISSION TO TRAVEL The defendant, Roger Bennett, respectfully moves this Court for permission to travel outside the District of Connecticut for business purposes. The details of the proposed business travel are set forth below. Mr. Bennett understands that Ms. Kattya Lopez at the U.S. Probation Office in Hartford has no objection to Mr. Bennett's proposed business travel. 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. Mr. Bennett is an accountant at Bennett & Company, P.C., located at 34 Jerome Avenue in Bloomfield, Connecticut. Bennett & Company is an accounting firm that has joined a group of accounting firms that intend to offer to its clients the ability to outsource to the firm the function of handling the clients' bookkeeping services. The group of accountants is called Bridge 21, which is conducting an orientation and training seminar on Thursday November 18, and Friday November 19, 2004 at the Alexis Park Hotel, 375 East Harmon, Las Vegas, Nevada. Mr. Bennett's proposed business trip is for the purpose of attending that seminar. To attend the Bridge 21 seminar, Mr. Bennett is scheduled to leave Connecticut on a US Airways flight from Bradley International Airport at approximately 5:55 p.m. on Wednesday, November 17, attend the conference on Thursday and Friday, and depart Las Vegas on Friday November 19 on a US Airways flight at approximately 11:55 p.m.

Case 3:03-cr-00129-JCH

Document 17

Filed 11/17/2004

Page 2 of 2

The following contact information is submitted with this motion: The phone number at the Alexis Park Hotel is 800-582-2228. On November 18 and 19, Mr. Bennett is scheduled to stay at the Stratosphere Hotel, 2000 Las Vegas Boulevard South, Las Vegas, Nevada; the phone number is 800-442-4002. Pursuant to Rule 7(b)(3), D. Conn. L. Civ. R., the undersigned counsel states that a voice mail message was left for AUSA Nardini late in the day on November 16, 2004 indicating the intent to file this motion. The undersigned has not received any communication from AUSA Nardini in response to that message. As noted above, the undersigned understands that Ms. Kattya Lopez at the U.S. Probation office in Hartford has no objection to Mr. Bennett's proposed business travel. 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 17th day of November, 2004 to: 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