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Motion to Continue Sentencing to April 26, 2023 — United States v. Michael Dimassa

Summary

Motion to Continue Sentencing to April 26, 2023, dated January 4, 2023 and filed as Document 237 in Criminal No. 3:22-cr-00033-OAW, United States v. Michael Dimassa. Counsel for the defendant asks to move his sentencing from March 8, 2023 to April 26, 2023 or a later date. The motion says he pleaded guilty on November 1, 2022 to Counts 1, 3 and 5 of the Indictment, has recently required emergency surgery and will need post-surgical medical treatment. It states that this is the first such request and that AUSA Raymond Miller has no objection.

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“Motion to Continue Sentencing to April 26, 2023 — United States v. Michael Dimassa.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-conn-no-3-22-cr-00033-dkt-237-d-conn-f835b1eb61/, SHA-256 32aaf719b3ffab0817f74edda6710a95fe5807210e4522cf4b3964578784a678.

Full text

        Case 3:22-cr-00033-OAW Document 237 Filed 01/04/23 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                                DISTRICT OF CONNECTICUT


UNITED STATES OF AMERICA                      :      CRIMINAL NO.3:22-cr-00033-OAW

               V.                             :

MICHAEL DIMASSA                               :      JANUARY 4, 2023


               MOTION TO CONTINUE SENTENCING TO April 26, 2023
       Pursuant to Local Rules of Criminal Procedure Rules 7 and 32 the Defendant,

MICHAEL DIMASSA, by and through the undersigned, hereby moves for a continuance of the

Defendant’s sentencing currently scheduled for March 8, 2023 to April 26, 2023. In support

hereof, counsel represents:

       1. On November 1, 2022 Defendant Michael Dimassa plead guilty to Counts 1,3 and 5

           of the Indictment charging three violations of 18 U.S.C §1349.

       2. Thereafter the Court scheduled Defendant’s sentencing for March 8, 2023 and set

           other attendant deadlines.

       3. Defendant has recently required emergency surgery and will require post-surgical

           medical treatment.

       4. Counsel requests a continuance of sentencing to no earlier than April 26, 2023, or

           such other date thereafter in the Court’s discretion, and the court set appropriate

           deadlines for the sentencing process:

           a. First Disclosure of the Presentence Report

           b. Objections to the Presentence Report

           c. 2nd Disclosure of Presentence Report

           d. Defendant’s Sentencing Memorandum
         Case 3:22-cr-00033-OAW Document 237 Filed 01/04/23 Page 2 of 3




           e. Government’s Sentencing Memorandum

           f. Defendant’s Reply (if any)

           g. Sentencing Date

       5. This is the first such request for a continuance of sentencing.

       6. Counsel for the United States of America, AUSA Raymond Miller, has no objection

           to the granting of this motion.




       WHEREFORE, the Counsel for Defendant respectfully requests that the Defendant’s

sentencing scheduled for March 8, 2023 be continued to April 26, 2023 or a future date at the

discretion of the Court.

                                      Respectfully Submitted,

                                      DEFENDANT, MICHAEL DIMASSA,



                                      /s/ John R. Gulash__________
                                      JOHN R. GULASH, ESQ.
                                      GULASH & ASSOCIATES, LLC
                                      PO BOX 999
                                      265 GOLDEN HILL STREET
                                      BRIDGEPORT, CT 06601
                                      EMAIL JRGulash@gulashlaw.com
                                      TEL 203-870-9944
                                      FAX 203-870-9838
                                      Fed Bar# ct05093
         Case 3:22-cr-00033-OAW Document 237 Filed 01/04/23 Page 3 of 3




                                       CERTIFICATION

        I hereby certify that on this date a copy of the foregoing was filed electronically and
served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by
email to all parties by operation of the Court’s electronic efile system, or by mail to anyone
unable to accept electronic filing, per indication on the Notice of Electronic Filing. Parties may
access this filing through the Court’s CM/ECF system.




                                            /s John R. Gulash__________
                                            JOHN R. GULASH
                                            GULASH & ASSOCIATES, LLC
                                            PO BOX 999
                                            265 GOLDEN HILL STREET
                                            BRIDGEPORT, CT 06601
                                            EMAIL JRGulash@gulashlaw.com
                                            TEL 203-870-9944
                                            FAX 203-870-9838
                                            Fed Bar# ct05093

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