Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:02-cr-00062-AWT

Document 199

Filed 08/07/2006

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STATESDISTRICTCOURT: LTNITED

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UNITED STATESOF AMERICA, -againstJOSECOSME,

(AWT) NO.3:01 CR00062 CzuMINAL August 2,2006

MOTION TO ADJOURNJURY SELECTION AND TRIAL

that throughundersigned counsel,requests the court adjoum the JOSECOSME,defendant jury selection trial in the captioned matteruntil October13,2006,for the following reasons: and

1.

the I am an attomeyadmittedto practicein this Court, represent captioneddefendant

I for and submitthis affidavit in supportofan application the relief requested. havepreviously my rmtil that samedate,aadamsubmittingthis motionto supplement prior requested continuance a application. The speedytrial waiver annexedto the prior application is made a part of this applicationasthoughmore fully setforth herein. for havebeenscheduled August11,2006. and 2. Juryselection trial in this case

of for 3. As indicatedin prior requests adjournments the trial in this case,I am currently to with the Govemment resolvethis case,as well as two other in engaged plea negotiations defendant.Theparameters which arealsopendingbeforethis courtinvolving the same Indictments havealready beendiscussed. disposition ofthe proposed

Case 3:02-cr-00062-AWT

Document 199

Filed 08/07/2006

Page 2 of 4

Court, Bronx to 4. I am alsoscheduled starta trial on August 7,2006, in the Supreme the of county, in the caseof the People the Stateof New York v. william senano.ln that case, defendant is charged with the crime of Attempted Murder and has been incarceratedfor to on two awaitingtrial. The trial was scheduled cornmence August 1,2006, approximately years a I but wasadjoumeduntil August7, 2006,because hadjust completed federalcriminal trial on July to for 28,2006,anddid not havetime to prepare the Bronxtrial. TheBronx trial is scheduled last approximatelytwo (2) weeksCounty,New Jersey, to to 5. Subsequent thattrial, I am scheduled begina trial in Passaic with murder.That trial will wheremy client is charged in the caseof the Statev. Anvoli Gonzalez, 6, start September 2006. 6. As the partieshavepreviouslyindicatedto this court, we believethat this matterwill be resolved,renderinga trial unnecessary. that we 7. For the foregoingreasons respectfullyrequest thecourtadjoumthetrial datefiom to Hall, hasno objection this by 13, AugustI 1,2006,until October 2006.TheGovemment, Gordon application. trial waiver, andconsented a has the 8. As previouslyindicated, defendant executed speedy of to the exclusion time until October13,2006.

Case 3:02-cr-00062-AWT

Document 199

Filed 08/07/2006

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Goldstein& Weinstein Attomeys for Defendant- JoseCosme Office andP.O.Address 888 Grand Concourse Bronx,New York 10451 (718)665-9000

Case 3:02-cr-00062-AWT

Document 199

Filed 08/07/2006

Page 4 of 4

CERTIFICATION OF SERVICE

This is to certi$ that a copy of foregoingwas mailed to AssistantUnited StatesAttomey, GordonHall, UnitedStates Attomey'sOffice for the District of Connecticut, ChurchStreet, l4l

. GOLDSTEIN