Professional Documents
Culture Documents
Defendant, Steven Humphries, through the undersigned counsel, hereby files this
Unopposed Motion to continue sentencing. The Government has advised counsel they do
not oppose this motion. In support of this unopposed motion, Defendant states the
following;
2. Since entering his plea, the Defendant has been fully compliant with all
conditions of his release including regularly reporting to probation in the Eastern District
insider trading case before the Honorable Adalberto Jordan (Case No. 09-CIV-21977).
6. Moreover, given the serious nature of the instant case, counsel requires
additional time to meet and confer with Mr. Humphries, who is located in Dallas, Texas,
will permit an opportunity for Mr. Humphries to fully put forth all efforts of complete
cooperation.
8. As such, counsel respectfully requests the Court permit a thirty (30) day
Defendant’s Unopposed Motion to continue his sentencing for thirty (30) days.
Under Local Rule 88.9(a), Christopher Bruno, Esq. hereby certifies that I have
conferred with Assistant United States Attorney Ryan Dwight O’Quinn, the lead
prosecutor in this case, and he has informed me that the Government has no objection to
this motion.
2
Case 0:10-cr-60259-WPD Document 33 Entered on FLSD Docket 01/19/2011 Page 3 of 4
_______/s/_______________
Gregg Jeffrey Breitbart
Florida Bar No. 843415
GUSRAE, KAPLAN, BRUNO &
NUSBAUM
2101 Northwest Corporate Boulevard
Suite 218
Boca Raton, Florida 33431
Telephone: (561) 910-5650
Facsimile: (561) 910-5652
_______/s/_________________
Christopher Bruno
Virginia Bar No. 47651
Bruno & Degenhardt, P.C.
10615 Judicial Drive, Suite 703
Fairfax, VA 22030
Telephone: (703) 352-8960
Facsimile: (703) 352-8930
3
Case 0:10-cr-60259-WPD Document 33 Entered on FLSD Docket 01/19/2011 Page 4 of 4
CERTIFICATE OF SERVICE
the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the
foregoing is being served this day on all counsel of record listed in the Service List below
authorized manner for those counsel or parties who are not authorized to receive
__________/s/______________________
Gregg J. Breitbart, Esq.
Service List