Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00057-JCH

Document 60

Filed 09/19/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. MILDRED MILLER

: September 19, 2006 : 3:03CR00057(JCH) :

GOVERNMENT'S MOTION TO CONTINUE SENTENCING AND FOR EXTENSION OF TIME TO FILE REPLY BRIEF On September 14, 2006, this Court entered an order rescheduling the re-sentencing of defendant Mildred Miller from September 26, 2006 to October 10, 2006 at 12:00 p.m. Unfortunately, this date and time directly conflict with an important matter which was scheduled over a month ago. Because the conflict involves a federal grand jury matter, counsel is unable to provide further details other than to assure the court that it concerns an important matter which cannot be changed. In addition, this is the first request for a continuance made by the Government. Accordingly, the Government respectfully requests that the sentencing be rescheduled to the week of October 16, 2006, or later. In connection with the anticipated re-sentencing of September 29, 2006, this Court entered a scheduling order requiring the defendant to file a sentencing memorandum by September 14, 2006 and the Government to respond by September 20, 2006. Government counsel returned to the office on September 18, 2006 after an absence of two weeks and respectfully requests additional time to reply to defendant's brief. This additional time would

Case 3:03-cr-00057-JCH

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enable counsel to more meaningfully review the issues raised by the defendant, and would in no way delay the sentencing. Accordingly, it is respectfully requested that an extension of time be granted to permit the filing of a response on or before October 3, 2006. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

By:

/S/___________________________ HAROLD H. CHEN ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. ct24432 JAMES G. GENCO ASSISTANT UNITED STATES ATTORNEY FEDERAL BAR NO. CT00360 450 MAIN STREET, ROOM 328 HARTFORD, CT 06103 (860) 947-1101

For:

Case 3:03-cr-00057-JCH

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Filed 09/19/2006

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CERTIFICATION OF SERVICE This is to certify that a copy of the within and foregoing has been faxed and mailed, first class, postage prepaid, this 19th day of September, 2006 to: Eileen F. Shapiro Attorney at Law 45 Washington Street #10 Brooklyn, NY 11201

By:

For:

/S/ HAROLD H. CHEN ASSISTANT UNITED STATES ATTORNEY JAMES G. GENCO ASSISTANT UNITED STATES ATTORNEY