Free Motion to Seal - District Court of Connecticut - Connecticut

Case 3:02-cr-00062-AWT

Document 244

Filed 10/25/2007

Page 1 of 3

UNITED STATES DISTRICT COURT: DISTRICT OF CONNECTICUT - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X UNITED STATES OF AMERICA,

-againstFAUSTO CANDELARIO, Defendant. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X

CRIMINAL NO.3 :02CR00062 (AWT) October 23, 2007

MOTION TO SEAL SENTENCING MEMORANDUM

FAUSTO CANDELARIO, defendant through undersigned counsel, requests that the court seal his sentencing memorandum for the following reasons:

1.

I am an attorney admitted to practice in this Court, represent the captioned defendant

and submit this affidavit in support of an application for the relief requested herein.

2.

The defendant entered guilty pleas under this indictment and two related Indictments

on March 20, 2007, and sentence is currently scheduled for sentence on October 29, 2007. Contemporaneously with the filing ofthis motion, a sentencing memorandum in aid ofsentence has been filed.

3.

The sentencing memorandum details the defendant's cooperation and the fact that we

anticipate the filing a "5K" motion.

4. Since cooperation is discussed in the sentencing memorandum, as well as in this motion, we asked that they be filed under seal.

Case 3:02-cr-00062-AWT

Document 244

Filed 10/25/2007

Page 2 of 3

DAVID J. GOLDSTEIN Goldstein & Weinstein Attorneys for Defendant-Fausto Candelario Office and P.O. Address 888 Grand Concourse Bronx, New York 10451 (718) 665-9000

Case 3:02-cr-00062-AWT

Document 244

Filed 10/25/2007

Page 3 of 3

CERTIFICATION OF SERVICE

This is to certify that a copy of foregoing was mailed to Assistant United States Attorney, Gordon Hall, United States Attorney's Office for the District of Connecticut, 141 Church Street, New Haven, Connecticut 06510, this 23rd day oforober, 2 q 07(\

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DAVID J. GOLDSTEIN