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

Case 3:02-cr-00257-CFD

Document 309

Filed 04/18/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. JACK WILLIAMS a.k.a. "Meat" a.k.a. "Monterey" : : : : : : Criminal No. 3:02cr257(CFD)

April 17, 2007

UNITED STATES' MOTION TO EXTEND TIME On or about March 19, 2007, the Court ordered the parties to simultaneously file briefs on or before April 18, 2007 as to whether a non-trivially different sentence should be imposed under the auspices of United States v. Booker. Based on a conversation with defense counsel, the government anticipates that the defendant will seek an extension of the filing date. In order to be able to respond to the defendant's

arguments, the undersigned respectfully requests that the Court allow the government to file its response ten days after the defendant's response is filed. Attorney David Wenc has no objection to this request. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

/s/ RAYMOND F. MILLER ASSISTANT UNITED STATES ATTORNEY 157 CHURCH STREET NEW HAVEN, CT (203) 821-3700 Federal Bar No. CT20451

Case 3:02-cr-00257-CFD

Document 309

Filed 04/18/2007

Page 2 of 2

-2CERTIFICATION I hereby certify that a copy of the foregoing motion was faxed on April 17, 2007, to David Wenc, Esq. 44 Main Street PO Box 306 Windsor Locks, CT 06096 /s/ RAYMOND F. MILLER ASSISTANT UNITED STATES ATTORNEY