Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:02-cr-00264-AHN

Document 2051

Filed 01/17/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------x UNITED STATES OF AMERICA : : Plaintiff, : : - against : : WALTER A. FORBES and : E. KIRK SHELTON : : Defendants. : ---------------------------------x

Criminal Action No. 3:02 CR 00264 (AWT)

JANUARY 17, 2006

CENDANT CORPORATION'S MOTION FOR LEAVE TO FILE A SURREPLY IN FURTHER OPPOSITION TO DEFENDANT E. KIRK SHELTON'S MOTION FOR STAY OF SENTENCE PROVIDING FOR RESTITUTION Cendant Corporation ("Cendant") hereby moves for an Order granting it leave to file a surreply memorandum of law in further opposition to defendant E. Kirk Shelton's Motion for Stay of Sentence Providing for Restitution (the "Stay Motion"). In support thereof, Cendant states that its request to file a surreply is based on new information that came to its attention after filing its opposition to the Stay Motion. Cendant believes that submission of a surreply memorandum is appropriate here in order to supplement the record with newly discovered information.

Case 3:02-cr-00264-AHN

Document 2051

Filed 01/17/2006

Page 2 of 3

Cendant's motion to file a surreply does not involve disputed issues of law and therefore no memorandum of law in support of Cendant's motion is submitted. See D. Conn. L. Civ. R. 7(a)(1) (made applicable herein by D. Conn. L. Cr. R. 1(c)). In support of its motion, Cendant submits its proposed surreply. WHEREFORE, Cendant respectfully requests that the Court grant this Motion and permit it to file the attached surreply in further opposition to the Stay Motion. Dated: Harford, Connecticut January 17, 2006 MOVANT - CENDANT CORPORATION

By: /s/ C. Donald Neville Robert E. Kaelin - ct11631 [email protected] C. Donald Neville ­ ct24001 [email protected] Murtha Cullina LLP CityPlace I - 185 Asylum Street Hartford, Connecticut 06103-3469 Telephone: (860) 240-6000 Facsimile: (860) 240-6150 Its Attorneys

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Case 3:02-cr-00264-AHN

Document 2051

Filed 01/17/2006

Page 3 of 3

Of Counsel: Samuel Kadet - ct07880 [email protected] SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Four Times Square New York, New York 10036-6522 Telephone: (212) 735-3000 Facsimile: (212) 735-2000
#858107

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