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

Case 3:01-cr-00179-SRU

Document 240

Filed 05/19/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. JEFFREY THOMAS

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CRIM. NO. 3:01CR179 (SRU)

MAY 19, 2008

UNITED STATES' MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO MODIFY SENTENCE On April 28, 2008, the defendant filed a pro se motion to modify his sentence pursuant to 18 U.S.C. § 3582(c)(2) (Doc. 238). On May 9, 2008, Assistant Federal Public Defender Diedre A. Murray filed a notice of appearance in this matter. Under Local Civil Rule of Civil Procedure 9(a)(1), incorporated by Local Rule of Criminal Procedure 1, the Government's motion is presently due today. The Government has been in contact with the United States Probation Office and is awaiting receipt of an Addendum setting for that's Office's position regarding the defendant's eligibility for a reduction. When that Addendum is received, the Government will respond to the defendant's motion. The Government would request that it permitted to respond to the defendant's motion on or before June 27, 2008. In this connection, the Government would note that the defendant's release ­ even if the Court were to grant the instant motion ­ is not imminent. According to the Bureau of Prisons Website, his present release date is December 2020 and any reduction could not reduce his sentence of 262 months to below the 240 month mandatory minimum in this case.

Case 3:01-cr-00179-SRU

Document 240

Filed 05/19/2008

Page 2 of 3

Ms. Murray has advised the undersigned that she has not objection to the request for a extension of time. Respectfully submitted, NORA R. DANNEHY ACTING UNITED STATES ATTORNEY

__/s/_______________________ ANTHONY E. KAPLAN ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct08083 23d Floor 157 Church Street New Haven, Connecticut 06510 (203) 821-3700

Case 3:01-cr-00179-SRU

Document 240

Filed 05/19/2008

Page 3 of 3

CERTIFICATION I hereby certify that on May 19, 2008, a copy of foregoing Government's Motion was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. __/s/_______________________ ANTHONY E. KAPLAN ASSISTANT U.S. ATTORNEY