Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:02-cr-00062-AWT

Document 215

Filed 12/29/2006

Page 1 of 3

STATESDISTRICTCOURT: LTNITED DISTRICTOF CONNECTICUT X
UNITED STATES OF AMERICA,

-againstJOSECOSME,

(AWT) CRIMINALNO. 3:02CR00062 26,2006 December

JOSE COSME, defendantthrough undersignedcounsel,requeststhat the court adjourn the jury selectionand trial in the captionedmaffer until March 13, 2007, for the following reasons:

l.

I am an afforney admitted to practice in this Court, representthe captioneddefendant

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

16,2007. for havebeenscheduled January and 2. Jury selection trial in this case DistrictCourtfor to 8,2007,Iamscheduled pick ajury in theUnitedStates 3. On January Helena of of District of New York in the case the UnitedStates Americav. Francisco the Eastern matter, dateasin theinstant 16,2007 same on to ,the Bellard.Trial is scheduled commence January beforethe HonorableEdwardR. Korman,Chief Judgeof that court. 4,2007, in the UnitedStates to scheduled pick a jury on January 4. I am alsocurrently in District Court, for the District of New Hampshire, the caseof the United Statesv. Gilberto of thereis no disposition thatmatter, J. the before Honorable GavinMurtha.In theevent Rodriguez,
LAW OFFICES GOT"DSTEIN VI'EINSIEIN & 888 GRAND CONCOURSE BRONX,NEW YORK 10451 (718)665-9000

Case 3:02-cr-00062-AWT

Document 215

Filed 12/29/2006

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trial is scheduledto commenceon January24'2006-

5. On January28,2007,I will commencea trial in the Superior Court for the Stateof New Jersey,passaic County, in the caseof the State v. Anyoli Gonzalez. That defendant is charged with to sinceApril 2004.That trial was scheduled occur in December, murder. and hasbeenincarcerated but was adjourned unti I January2007,becauseof issuesconcerning the competencyofthe defendant. Those issues will be resolved prior to the trial date. The trial in that case is expected to last approximately 3 weeks.

6. For the foregoing reasonswe respectfully requestthat the court continue the trial date from January 16,2007,until March 13,2007. The Government,by Gordon Hall, has no objection to this application.

7. The defendant will executed a speedy trial waiver, which will be filed separately, to consenting the exclusionof time until March 13,2007 ("Exhibit A").

DAVID J. & Goldstein Weinstein Attorneysfor Defendant- JoseCosme OffrceandP.O.Address 888 GrandConcourse Bronx,New York 10451 (718)665-9000

LAW OFFICES GOTI\gTEIN & WEINSIEIN 888 GRAND CONCOURSE BRONX,NEW YORK10451 (718)665-9000

Case 3:02-cr-00062-AWT

Document 215

Filed 12/29/2006

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CERTIFICATION OF SERVICE
This is to certiff that a copy of foregoing was mailed to Assistant United StatesAttorney, Street, Gordon Hall, United SiatesAttorney's Office for the District of Connecticut, 141 Church

06510,this 2fth dayof Deceftr\er, New Haven,Connecticut

DAVID J.

LDSTEIN

LAWOFFICES GOIDSTEIN lrlrElNSTElN & CONCOURSE 888GRAND BRONX, NEWYORK10451 (718) 665-9000