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

Case 3:02-cr-00313-AWT

Document 56

Filed 08/25/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. RAYMOND ORTIZ : : : CRIMINAL NO. 3:02CR313(AWT) : : AUGUST 25, 2006

GOVERNMENT'S MOTION FOR EXTENSION OF TIME, NUNC PRO TUNC On June 12, 2006, the Court granted defendant Raymond Ortiz' Motion for Extension of Time to File Response to Endorsement Order, until August 1, 2006. Counsel for the Government requests an extension of time of two weeks, until September 5, 2006, to respond to defendant's Motion for Resentencing pursuant to United States v. Crosby. In support of this request, the undersigned avers that his three-week absence from this District, from July 28, 2006 until August 17, 2006, combined with the press of business, necessitates this request for an extension of time. This motion is the first filed by the Government seeking an extension of time to respond. Defense counsel, Bethany Phillips, Esq., has been contacted and has not objection to this request. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

BY:

JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY Federal Bar No. CT05101 THOMAS V. DAILY ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct05101 450 Main Street Hartford, CT 06103 (860) 947-1101

For:

Case 3:02-cr-00313-AWT

Document 56

Filed 08/25/2006

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that the foregoing was mailed this 25th day of August, 2006, to the following: Bethany Lynne Phillips, Esq. Advocates Law Firm 11 Franklin Square New Britain, CT 06051-2604

By:

__________________________ JOHN A. DANAHER III ASSISTANT UNITED STATES ATTORNEY

FOR: THOMAS V. DAILY ASSISTANT UNITED STATES ATTORNEY

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