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

Case 3:02-cr-00007-JBA

Document 1375

Filed 04/29/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA V. WILFREDO PEREZ : APRIL 29, 2005 : CRIMINAL NO. 3:02CR7 (JBA)

MOTION FOR LEAVE TO FILE BRIEF IN EXCESS OF FORTY PAGES The defendant, Wilfredo Perez, respectfully moves this Court for leave to file athe accompanying 44-page memorandum in support of his motion for a new trial. In support of this Motion, defendant states the following grounds: (1) Mr. Perez was found guilty on Counts I, II, IV and V of the Indictment by a jury on June 29, 2004, and now faces a mandatory life sentence. (2) Counsel for Mr. Perez has prepared a memorandum in support of the motion for a new trial, and it exceeds the 40-page limit set forth in Rule 7(a)(2) of the Local Rules of Civil Procedure, made applicable to criminal cases by Rule 1(c) of the Local Rules of Criminal Procedure. (3) In order to adequately brief the issues involved here, counsel for Mr. Perez found it necessary to provide detailed citations to the lengthy trial transcript, and in some areas has included quotes from various transcripts; these materials are voluminous, and have led to the brief exceeding the 40-page limit. WHEREFORE, it is respectfully requested that defendant Wilfredo Perez be permitted to file a memorandum in support of the motion for a new trial which exceeds the 40-page limit.

Case 3:02-cr-00007-JBA

Document 1375

Filed 04/29/2005

Page 2 of 2

Respectfully submitted, THE DEFENDANT, WILFREDO PEREZ

April 29, 2005

/s/ Richard A. Reeve Sheehan & Reeve 139 Orange Street, Suite 301 New Haven, CT 06510 Federal Bar No. ct05084 (203)787-9026 (203) 787-9031 (fax) [email protected]

CERTIFICATE OF SERVICE I hereby certify that copies of the MOTION FOR LEAVE TO FILE BRIEF IN EXCESS OF FORTY PAGES have been sent by first class mail, postage prepaid, to the following counsel of record as listed below, this 29th day of April, 2005: David Ring, Esq. David Vatti, Esq. Assistant U.S. Attorneys PO Box 1824 New Haven, CT 06508 William T. Koch, Jr. 151 Brush Hill Rd. Lyme, CT 06371

/s/ Richard A. Reeve

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