Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:02-cr-00329-AHN

Document 82

Filed 09/25/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. RAMEK GORDON : : : CRIMINAL NO. 3:02CR329(AHN) September 22, 2006

MOTION ON CONSENT TO CONTINUE SENTENCING

The defendant, Ramek Gordon, hereby moves to continue sentencing, from September 29, 2006 until a date on or about November 27, to permit him to fulfill his cooperation agreement, before he is sentenced, by testifying in a case that is scheduled for trial on October 19, 2006. In support of this motion, counsel for Mr. Gordon states the following grounds: 1. On March 21, 2003, he pled guilty to Count Two of the Indictment, which charged him with possession with intent to distribute fifty or more grams of cocaine base, in violation of 21 U.S.C. § §841(a)(1) and 841(b)(1)(A). 2. Sentencing has been continued several times so Mr. Gordon could testify in United States v. Gary Mills, 3:03CR32(PCD), which had been delayed until now because of a pending interlocutory appeal. Pursuant to his cooperation agreement, Mr. Gordon previously testified in United States v. Arnold Bell, 3:03CR230(AHN). 4. Counsel for the government consents to this motion. 5. Mr. Gordon is incarcerated pending sentencing.

Case 3:02-cr-00329-AHN

Document 82

Filed 09/25/2006

Page 2 of 2

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Respectfully submitted, THE DEFENDANT, RAMEK GORDON THOMAS G. DENNIS FEDERAL DEFENDER

Dated: September 22, 2006

/s/ Paul F. Thomas Asst. Federal Defender 2 Whitney Ave., Suite 300 New Haven, CT 06510 Bar No. ct01724 (203) 498-4200

CERTIFICATION I HEREBY CERTIFY that a copy of the foregoing MOTION TO CONTINUE SENTENCING has been mailed to Anthony Kaplan, Assistant United States Attorney, P.O. Box 1824, New Haven, CT 06508, and to Mark D. Myers, United States Probation Officer, 157 Church Street, New Haven, CT 06510, on this 22nd day of September, 2006.

/s/ Paul F. Thomas