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

Case 3:01-cr-00155-AVC

Document 29

Filed 09/22/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. CHERYL DEANDRADE : : : CRIMINAL NO. 3:05CR286(AVC) 3:05CR155(AVC) September 15, 2006

UNOPPOSED MOTION TO EXTEND VOLUNTARY SURRENDER DATE The defendant respectfully moves the Court to extend her voluntary surrender date (currently September 25, 2006) so that the Bureau of Prisons may designate her to an institution. She has not yet been designated. The United States Marshal's Office suggests, and the defendant so moves, that the Court enter an order indicating that Ms. Deandrade is to surrender for service of sentence "as notified by the United States Marshal." Such an order will permit the designation process to be completed and will avoid the need to repeatedly file motions to address the self-surrender date. The defendant was sentenced on August 3, 2006 and ordered to voluntarily surrender to the "institution designated by the Bureau of Prisons... on September 18, 2006." That date was extended until September 25, 2006 because the Bureau of Prisons had not yet designated her. At present, fulfilling this order is an impossibility since the Bureau of Prisons still has failed to designate the defendant to any institution. In addition, however, there are medical issues that make it important for the defendant to surrender to an institution that is ready to address her medical needs. As set forth in the letter from her doctor (previously provided to the Court), the defendant requires the use of a catheter and medication in order to urinate. Typically, institutions do not allow prisoners to bring such items. Thus, it is important that the institution to which she is designated have notice of her medical requirements. Because the Bureau of Prisons has not yet designated the defendant, it has been impossible to make such arrangements. Counsel for the government has no objection to the granting of this motion. WHEREFORE, the defendant respectfully moves the Court to extend her voluntary surrender date so that the Bureau of Prisons may designate her to an institution and order that she

Case 3:01-cr-00155-AVC

Document 29

Filed 09/22/2006

Page 2 of 2

-2surrender "as notified by the United States Marshal.

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Respectfully submitted, The Defendant, Cheryl Deandrade Thomas G. Dennis Federal Defender

Dated: September 22, 2006

/s/ Terence S. Ward Asst. Federal Defender 10 Columbus Blvd, FL 6 Hartford, CT 06106-1976 Bar No. Ct00023 (860) 493-6260 Email: [email protected] CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing unopposed motion to extend has been mailed to James G. Genco, Assistant United States Attorney, Federal Building, 450 Main Street, Hartford, CT 06103, on this 22 day of September 2006.

/s/ Terence S. Ward