Free Motion for Reconsideration - District Court of Connecticut - Connecticut

Case 3:02-cr-00334-PCD

Document 114

Filed 09/28/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. HERMAN JAMES SEPTEMBER 26, 2006 MOTION FOR RECONSIDERATION The defendant Herman James moves that the Court reconsider the issues raised and the facts presented relating to departure issues on his behalf at the previous sentencing. The defendant represents that pursuant to U.S. vs. Fagans, 406 F.3rd 138 (2nd Cir. 2005), the defendant is entitled to be resentenced, and to have the Court reconsider such issues. Respectfully submitted, DEFENDANT, HERMAN JAMES BY______________________________ JONATHAN J. EINHORN, ESQ. 412 ORANGE STREET NEW HAVEN, CT 06511 TELEPHONE: (203) 777-3777 FACSIMILE : (203) 782-1721 Email address: [email protected] Fed. Bar No. ct00163 CERTIFICATION It is hereby certified that a copy of the foregoing was sent via first class mail, postage prepaid, this 26th day of September, 2006 to the following counsel of record: John Marrella, Esq. Assistant U.S. Attorney 157 Church Street, 23rd Floor P.O. Box 1824 New Haven, Connecticut 06510 ________________________________ JONATHAN J. EINHORN CRIM. NO. 3:02cr334 (PCD)

Case 3:02-cr-00334-PCD

Document 114

Filed 09/28/2006

Page 2 of 2