Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cr-00032-PCD

Document 91

Filed 01/05/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. GARY MILLS : : : No. 3:06CR32 PCD JANUARY 2, 2007

MOTION TO CONTINUE SENTENCING 1. Sentencing in the above-captioned matter is currently scheduled for January 11, 2007. 2. The defendant is confined at the Wyatt Detention Center in Central Falls, Rhode Island. 3. Although the defendant was sent a copy of the pre-sentence report, the undersigned has, as of yet, not had the opportunity to sit down with Mr. Mills and go over that report paragraph by paragraph. 4. Counsel attempted to go to Wyatt on December 30, 2006. Because of various logistical problems, he was only able to spend ten minutes with Mr. Mills at that time. 5. Counsel is scheduled to start trial on January 4, 2007, in the case of United States of America v. Rohan Purcell before Judge Thompson in Hartford. 6. Because of the length of that trial and the work involved, counsel will probably not have another opportunity to visit with Mr. Mills at Wyatt before January 11, 2007.

Case 3:03-cr-00032-PCD

Document 91

Filed 01/05/2007

Page 2 of 3

WHEREFORE, the undersigned respectfully requests that the sentencing be continued for two weeks. The Government does not oppose the granting of this request. Respectfully submitted, DEFENDANT, GARY MILLS

By:__________________________ Richard S. Cramer 250 Hudson Street Hartford, CT 06106 (860) 560-7704 Federal Bar No. ct00016 Email: cramer @ snet.net

Case 3:03-cr-00032-PCD

Document 91

Filed 01/05/2007

Page 3 of 3

CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing was mailed this 2nd day of January 2007 to: John Durham Assistant U. S. Attorney 157 Church Street New Haven, CT 06510

__________________________ Richard S. Cramer