Trow Bridge Sentencing Set Aside
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Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 1 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant.
NOTICE OF MOTION TO ADJOURN SENTENCING PLEASE TAKE NOTICE that upon the annexed Affidavit of Robert C. Moscati, Assistant United States Attorney, the undersigned moves this Court for an adjournment of the sentencing currently set for Thursday, July 31, 2008.
DATED:
Buffalo, New York, July 10, 2008. TERRANCE P. FLYNN United States Attorney BY:
TO:
S/ROBERT C. MOSCATI Assistant U.S. Attorney U.S. Attorney’s Office Western District of New York 138 Delaware Avenue Buffalo, New York 14202 (716) 843-5700, ext. 869 [email protected]
David C. Douglas, Esq. Diane Root, U.S. Probation Officer
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 2 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant. GOVERNMENT’S AFFIDAVIT IN SUPPORT OF MOTION TO ADJOURN SENTENCING STATE OF NEW YORK) COUNTY OF ERIE ) SS: CITY OF BUFFALO ) ROBERT C. MOSCATI, being duly sworn, deposes and states: 1.
I am the Assistant United States Attorney for the Western
District of New York assigned to the prosecution of the aboveentitled action.
This affidavit is submitted in support of the
Government’s motion for an adjournment of the sentencing currently scheduled for July 31, 2008, before United States District Judge William M. Skretny.
2.
On March 20, 2008, the defendant appeared before this
Court, waived Indictment and pled guilty to a 1 count Information charging him with a violation of Title 18, United States Code, Section
2421,
Transportation
of
an
Individual
in
Interstate
Commerce with Intent that the Individual Engage in Prostitution Mann Act).
Sentencing was set for July 31, 2008.
Case 1:08-cr-00074-WMS
3.
Document 7
Filed 07/10/2008
Page 3 of 5
The plea agreement in this case calls for cooperation
with the Government on the part of the defendant (Section VII). The
Cooperation
section
of
the
plea
agreement
requires
the
defendant to testify truthfully before grand juries and at such pre-trial and trial proceedings as the government shall deem necessary (Paragraph 22) and states that the parties will request that
sentencing
be
adjourned
until
full
satisfaction
by
the
defendant of the terms of this agreement (Paragraph 33).
4.
While the defendant has assisted the Government fully and
completely to date, he has not completed all of the terms of his contemplated
cooperation
at
this
time.
At
this
point,
Mr.
Trowbridge’s testimony in related proceedings is still possible and would be required by the Government.
Accordingly, the Government
respectfully requests the defendant’s sentencing date be adjourned sine
die
with
cooperation
the
has
Government
been
to
advise
completed.
the
Court
Alternatively,
when
such
perhaps
a
sentencing status conference may be appropriate in 90-120 days. Certainly if sentencing could proceed prior thereto, the Government would so advise the Court.
8.
I have spoken with counsel for the defendant, David C.
Douglas, regarding this request and he has no objection to the granting of this motion by the Court.
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 4 of 5
WHEREFORE, it is respectfully requested that the Court grant an adjournment of the sentencing date currently set for Thursday, July 31, 2008.
S/ROBERT C. MOSCATI Assistant U.S. Attorney United States Attorney’s Office Western District of New York 138 Delaware Avenue Buffalo, New York 14202 (716) 843-5700, ext. 869 [email protected] Sworn to before me this 10th day of July, 2008. S/MADELINE C. MARRONE Commissioner of Deeds In And For The City of Buffalo, New York My Commission Expires December 31, 2008
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 5 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant. CERTIFICATE OF SERVICE
I hereby certify that on July 10, 2008, I electronically filed the attached NOTICE OF MOTION TO ADJOURN SENTENCING AND SUPPORTING AFFIDAVIT, with the Clerk of the District Court using its CM/ECF system.
I also certify that I mailed the foregoing via United
States mail to the following participants on this case: David C. Douglas, Esq. 365 Market Street P.O. Box 468 Lockport, New York 14095 United States Probation Department Attn: Diane Root U.S. Probation Officer
S/MADELINE C. MARRONE
Document 7
Filed 07/10/2008
Page 1 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant.
NOTICE OF MOTION TO ADJOURN SENTENCING PLEASE TAKE NOTICE that upon the annexed Affidavit of Robert C. Moscati, Assistant United States Attorney, the undersigned moves this Court for an adjournment of the sentencing currently set for Thursday, July 31, 2008.
DATED:
Buffalo, New York, July 10, 2008. TERRANCE P. FLYNN United States Attorney BY:
TO:
S/ROBERT C. MOSCATI Assistant U.S. Attorney U.S. Attorney’s Office Western District of New York 138 Delaware Avenue Buffalo, New York 14202 (716) 843-5700, ext. 869 [email protected]
David C. Douglas, Esq. Diane Root, U.S. Probation Officer
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 2 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant. GOVERNMENT’S AFFIDAVIT IN SUPPORT OF MOTION TO ADJOURN SENTENCING STATE OF NEW YORK) COUNTY OF ERIE ) SS: CITY OF BUFFALO ) ROBERT C. MOSCATI, being duly sworn, deposes and states: 1.
I am the Assistant United States Attorney for the Western
District of New York assigned to the prosecution of the aboveentitled action.
This affidavit is submitted in support of the
Government’s motion for an adjournment of the sentencing currently scheduled for July 31, 2008, before United States District Judge William M. Skretny.
2.
On March 20, 2008, the defendant appeared before this
Court, waived Indictment and pled guilty to a 1 count Information charging him with a violation of Title 18, United States Code, Section
2421,
Transportation
of
an
Individual
in
Interstate
Commerce with Intent that the Individual Engage in Prostitution Mann Act).
Sentencing was set for July 31, 2008.
Case 1:08-cr-00074-WMS
3.
Document 7
Filed 07/10/2008
Page 3 of 5
The plea agreement in this case calls for cooperation
with the Government on the part of the defendant (Section VII). The
Cooperation
section
of
the
plea
agreement
requires
the
defendant to testify truthfully before grand juries and at such pre-trial and trial proceedings as the government shall deem necessary (Paragraph 22) and states that the parties will request that
sentencing
be
adjourned
until
full
satisfaction
by
the
defendant of the terms of this agreement (Paragraph 33).
4.
While the defendant has assisted the Government fully and
completely to date, he has not completed all of the terms of his contemplated
cooperation
at
this
time.
At
this
point,
Mr.
Trowbridge’s testimony in related proceedings is still possible and would be required by the Government.
Accordingly, the Government
respectfully requests the defendant’s sentencing date be adjourned sine
die
with
cooperation
the
has
Government
been
to
advise
completed.
the
Court
Alternatively,
when
such
perhaps
a
sentencing status conference may be appropriate in 90-120 days. Certainly if sentencing could proceed prior thereto, the Government would so advise the Court.
8.
I have spoken with counsel for the defendant, David C.
Douglas, regarding this request and he has no objection to the granting of this motion by the Court.
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 4 of 5
WHEREFORE, it is respectfully requested that the Court grant an adjournment of the sentencing date currently set for Thursday, July 31, 2008.
S/ROBERT C. MOSCATI Assistant U.S. Attorney United States Attorney’s Office Western District of New York 138 Delaware Avenue Buffalo, New York 14202 (716) 843-5700, ext. 869 [email protected] Sworn to before me this 10th day of July, 2008. S/MADELINE C. MARRONE Commissioner of Deeds In And For The City of Buffalo, New York My Commission Expires December 31, 2008
Case 1:08-cr-00074-WMS
Document 7
Filed 07/10/2008
Page 5 of 5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v.
08-CR-74-S
JOHN TROWBRIDGE, Defendant. CERTIFICATE OF SERVICE
I hereby certify that on July 10, 2008, I electronically filed the attached NOTICE OF MOTION TO ADJOURN SENTENCING AND SUPPORTING AFFIDAVIT, with the Clerk of the District Court using its CM/ECF system.
I also certify that I mailed the foregoing via United
States mail to the following participants on this case: David C. Douglas, Esq. 365 Market Street P.O. Box 468 Lockport, New York 14095 United States Probation Department Attn: Diane Root U.S. Probation Officer
S/MADELINE C. MARRONE
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