Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:01-cr-00286-RNC

Document 45

Filed 02/14/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA V. CHARLES J. HOBLIN : : : : :

NO. 3:01CR286 (RNC) FEBRUARY 11, 2005

EMERGENCY MOTION TO DELAY SELF-SURRENDER On January 5, 2005, the Honorable Robert N. Chatigny sentenced the Defendant and further ordered the Defendant to voluntarily surrender on Monday, 2/14/05 either to a place designated by the Bureau of Prisons or to the U.S. Marshal for the District of Connecticut. The undersigned has been attempting to determine the place of designation this entire week (the week of February 7, 2005.), and as of Friday, February 11, 2005 no such designation has been received from the Bureau of Prisons. The Defendant is 71 years of age and is not in the best of health. It is requested that a reporting date be extended for a period not to exceed 30 days within which it is hoped that the Bureau of Prisons will designate a specific location for Mr. Hoblin to which he can selfsurrender. To place a 71 year old man "in transit" for a substantial period of time before he arrives at his ultimate designation would be an extreme hardship upon him. The undersigned has contacted Assistant U.S. Attorney Calvin B. Kurimai, and he has no objection to this request. THE DEFENDANT CHARLES J. HOBLIN

By /s/ Frank J. Riccio . FRANK J. RICCIO LAW OFFICES OF FRANK J. RICCIO LLC P.O. BOX 491 BRIDGEPORT CT 06601-0491 (203) 333-6135 (Phone) (203) 333-6190 (Fax) Fed. Bar #CT 00148

Case 3:01-cr-00286-RNC

Document 45

Filed 02/14/2005

Page 2 of 2

CERTIFICATION This is to certify that a copy of the foregoing was faxed to: 1 (860) 240-3211, Linda Kunofsky, Court Room Clerk for the Honorable Robert N. Chatigny, U.S.D.J., U.S. District Court House, 450 Main Street, Hartford, CT 06106 and mailed to: Calvin B. Kurimai, Asst. U.S. Attorney, U.S. District Court, District of Connecticut, 157 Church Street, 23rd floor, New Haven, CT 06510, and Otto Rothi, U.S.Probation Officer, U.S. Courthouse, 450 Main Street, Room 735, Hartford, CT 06103 on February 11, 2005.

By /s/ Frank J. Riccio . FRANK J. RICCIO LAW OFFICES OF FRANK J. RICCIO LLC