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

Case 3:02-cr-00341-EBB

Document 587

Filed 10/28/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. SHORELINE MOTORS, ET AL : : : NO. 3:02CR341 (EBB) OCTOBER 27 2005

MOTION FOR EXTENSION OF TIME TO FILE BRIEFS The defendant, DAVID BROWN, through his undersigned counsel, respectfully requests that the time for the filing of defense briefs in support of a motion for a judgment of acquittal, Fed. R. Cr. P. 29 (c) and for a motion to grant a new trial, Fed. R. Cr. P. 33(b)(2), be extended until November 2, 2005. The defendant is a solo practitioner with no associates. Counsel has substantially completed the brief but needs to make minor modifications. Unfortunately, the undersigned, a solo practitioner, has one secretary who, because of a child care situation, will be unavailable Friday, October 28, 2005, and Monday, October 31, 2005. The finishing touches on the brief, therefore, cannot be completed until the morning of November 1, 2005. Assistant U. S. Attorney Jonathan Biran does not oppose the granting of this request. WHEREFORE, the undersigned respectfully requests one final extension until November 2, 2005.

Case 3:02-cr-00341-EBB

Document 587

Filed 10/28/2005

Page 2 of 2

DEFENDANT, DAVID BROWN

By:________________________________ Richard S. Cramer 449 Silas Deane Highway Wethersfield, CT 06109 Tel. (860) 257-3500 Federal Bar No. ct00016 Email: [email protected]