Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:02-cr-00341-EBB

Document 794

Filed 02/02/2007

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. ANGEL HERNANDEZ, et al.

: : : : :

CRIMINAL NUMBER: 3:02CR341 (EBB)

February 2, 2007

MOTION FOR EXTENSION OF TIME TO FILE A MEMORANDUM REGARDING THE LOSS AMOUNTS

The United States of America, by and through the undersigned Assistant U.S. Attorney, respectfully requests an extension of time of 5 days until February 7, 2007, to file its memorandum regarding the loss amounts in the above-captioned matter. This is the Government's first request for an extension. In support of this motion, the Government states the following: 1. case. 2. On January 18, 2007, the Court issued an order requesting that the defendants On September 19, 2006, a hearing was held regarding the restitution loss in the

and the government file briefs regarding the loss amount and restitution. 3. The undersigned counsel represents that he will not read the briefings filed

by the defendants in this case until after filing its submission.

ORAL ARGUMENT NOT REQUESTED

-1-

Case 3:02-cr-00341-EBB

Document 794

Filed 02/02/2007

Page 2 of 3

4.

Attorney for the government has attempted to contact all counsel, counsel for

defendant Richard Brown does not object; counsel for David Brown takes no position; messages were left for counsel for Mr. Hernandez and Mr. Datil. 5. 21, 2007. Accordingly, the Government respectfully requests that the Court grant an extension of time for filing of its memorandum regarding restitution loss amounts until February 7, 2007. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY Parties request that the date for the reply brief be extended 5-days until February

By:

CHRISTOPHER W. SCHMEISSER ASSISTANT UNITED STATES ATTORNEY Federal Bar No.: ct14806

For:

MICHAEL S. McGARRY ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct25713 157 CHURCH STREET NEW HAVEN, CONNECTICUT 06510 (203) 821-3700 Email: [email protected]

-2-

Case 3:02-cr-00341-EBB

Document 794

Filed 02/02/2007

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that on February 2, 2007, a copy of the foregoing was served by U.S. Mail on the following persons: Robert C. Mirto, Esq. Mirto, Ketaineck, Barrett & DiCrosta P.O. Box 428 West Haven, CT 06516 (counsel for David Brown) Michael S. Hillis, Esq. Dombroski Knapsack & Hillis LLC 129 Whitney Avenue New Haven, CT 06511 (counsel for Richard Brown) Kurt F. Zimmermann, Esq. Silverstein and Osach, P.C. 234 Church Street, Suite 903 New Haven, CT 06510 (counsel for Angel Hernandez) Jonathan J. Einhorn, Esq. 412 Orange Street New Haven, CT 06511 (counsel for Nelson Datil)

By: CHRISTOPHER W. SCHMEISSER ASSISTANT U.S. ATTORNEY

For:

MICHAEL S. McGARRY ASSISTANT UNITED STATES ATTORNEY

-3-