Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:01-cr-00286-RNC

Document 36

Filed 11/17/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. CHARLES J. HOBLIN : : : : : NO. 3:01CR286 (RNC) NOVEMBER 15, 2004

DEFENDANT'S MOTION TO CONTINUE SENTENCING The undersigned counsel for Charles J. Hoblin respectfully moves this Court to continue the sentencing in the above-entitled action, currently scheduled for December 3, 2004 @ 11:00pm for thirty days until January 3, 2005 for the following reasons: 1) Given the unsettled legal environment created through the United States Supreme

Court consideration of Blakely v. Washington as well as the anticipated decisions in United States v. Booker and United States v. Fanfan, the undersigned submits that a continuance of this case to early January 2005 would serve the interests of justice. 2) By early 2005, the dust will have settled as to the legal implications of Booker and Fanfan, whatever that may be, and this sentencing can take place without further delay.
The undersigned has contacted Asisstant United States Attorney Calvin B. Kurimai, and he does not consent to this extension request. RESPECTFULLY SUBMITTED CHARLES J. HOBLIN By /s/ Frank J. Riccio . FRANK J. RICCIO LAW OFFICES OF FRANK J. RICCIO LLC 923 EAST MAIN STREERT PO BOX 491 BRIDGEPORT CT 06601-0491 (203) 333-6135 (phone) (203) 333-6190 (fax) Fed Bar #CT 00148 www.ricciolaw.com

Case 3:01-cr-00286-RNC

Document 36

Filed 11/17/2004

Page 2 of 2

CERTIFICATION This is to certify that a copy of the foregoing was mailed to: Calvin B. Kurimai, Esq., Assistant United States Attorney, United States District Court, District of Connecticut, 157 Church Street, 23rd Floor, New Haven, CT 06510; to Otto Rothi, United States Probation Officer, United States Courthouse, 450 Main Street, Room 735, Hartford, CT 06103; and a complimentary chambers copy to the Honorable Robert N. Chatigny, U.S.D.J., United States District Courthouse, 450 Main Street, Hartford, CT 06106.

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