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

Case 3:02-cr-00007-JBA

Document 1340

Filed 02/28/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA V. WILFREDO PEREZ : FEBRUARY 25, 2005 : CRIMINAL NO. 3:02CR7 (JBA)

SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF IN SUPPORT OF MOTION FOR NEW TRIAL The defendant, Wilfredo Perez, respectfully moves this Court for a second extension of time to file a brief in support of his Motion for a New Trial, from February 28, 2005 until March 31, 2005. 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. (2) On July 12, 2004, the Court ordered counsel to file any Motion for New Trial on or before August 13, 2004, and further ordered "memorandum[s] in support to be filed 45 days following receipt of transcripts" (Doc. # 1085). (3) On August 11, 2004, the defendant timely filed his motion for new trial (Doc. # 1144). (4) This Court granted an extension of time until February 28, 2005 to file the supporting Memorandum. (5) Counsel for Mr. Perez are still engaged in a state capital habeas proceeding, in which testimony is now expected to finish on March 4, 2005. (6) As a result of this and other obligations, counsel is unable to file the memorandum by the present due date of February 28, 2005.

Case 3:02-cr-00007-JBA

Document 1340

Filed 02/28/2005

Page 2 of 3

(7) Counsel has been advised by A.U.S.A. David Ring that the government is not opposed to this request for an extension of time in which to file this brief. (8) This is the second request for an extension of time to file the memorandum in support of the motion for a new trial. WHEREFORE, it is respectfully requested that defendant Wilfredo Perez be given until March 31, 2005 to file his memorandum in support of the motion for a new trial. Respectfully submitted, THE DEFENDANT, WILFREDO PEREZ

February 25, 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]

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Case 3:02-cr-00007-JBA

Document 1340

Filed 02/28/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that copies of the SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF IN SUPPORT OF MOTION FOR NEW TRIAL have been sent by first class mail, postage prepaid, to the following counsel of record as listed below, this 25th day of February, 2005: David Ring, Esq. Assistant U.S. Attorney 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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