Free Motion to Reduce Sentence re Crack Cocaine Offense - 18:3582 - District Court of Connecticut - Connecticut

Case 3:02-cr-00191-CFD

Document 680

Filed 03/14/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. VICENTE OJEDA MARCH 14, 2008 NO. 3:02cr191 (CFD)

MOTION OF DEFENDANT VICENT OJEDA RE: REDUCTION OF SENTENCE CRACK COCAINE OFFENSE 18 U.S.C. § 3582 Defendant Vicente Ojeda, in the above-captioned criminal matter, through counsel, respectfully moves the Court hereby to reduce the sentence imposed upon him by the Court on May 24, 2005, pursuant to 18 U.S.C. §3582 and the recent amendments to the sentencing guidelines governing crack cocaine offenses. In this regard, defendant cites the attached Addendum to the Presentence Report. In this Addendum, Probation recommends as revised Guide Range of 120 to 150 months, and advises the Court that Defendant's new release date after the reduction called for by the amended guidelines is July 18, 2008. WHEREFORE, in light of the foregoing , and the Addendum prepared by and submitted by the United States Probation Office, Defendant respectfully moves this Court to grant this motion to reduce Defendant's sentence pursuant to 18 U.S.C. §3582 and in light of Amendment 706 to the United States Sentencing Guidelines.

Case 3:02-cr-00191-CFD

Document 680

Filed 03/14/2008

Page 2 of 2

Defendant respectfully moves that his motion be granted. RESPECTFULLY SUBMITTED, DEFENDANT, VICENTE OJEDA BY ______________________ JONATHAN J. EINHORN, ESQ. 412 ORANGE STREET NEW HAVEN, CONNECTICUT 06511 203-777-3777 FEDERAL BAR NO. ct00163

CERTIFICATION I hereby certify that on March 14, 2008, a copy of the foregoing Motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. ___________________________ JONATHAN J. EINHORN