Case 3:14-cr-00201-JAM Document 32 Filed 11/05/14 Page 1 of 3

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA
PLAINTIFF
V.

ROBERT E. LEE, JR.

DEFENDANT

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CRIMINAL NO.: 3:14cr201 (JAM)

NOVEMBER 5, 2014

MOTION TO CONTINUE JURY SELECTION

The defendant, ROBERT E. LEE, JR., through counsel, hereby moves this Honorable
Court to continue Jury Selection currently scheduled for January 14, 2015 to March 16, 2015,
and to amend the scheduling order to allow defendant's motions to be due by January 5, 2015
and the government's response to be due by January 19, 2015 and states in support the
following:

1.

That the defendants ongoing chemotherapy treatment causes extreme fatigue

which renders him unable to promptly assist Counsel in his defense;

2.

That Counsel for the defendant has attached a letter from the defendants
oncologist as exhibit A;

3.

It would be in the interest of justice for the Court to grant this motion;

4.

Counsel has been in contact with the government, and the government objects
to the granting of this motion.

5.

A waiver of speedy trial affidavit is attached hereto.

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WHEREFORE, defendant prays this Court enter an Order to continue Jury Selection
currently scheduled for January 14, 2015 to March 16, 2015, and to amend the scheduling order
to allow defendant's motions to be due by January 5, 2015 and the government's response to
be due by January 19, 2015.

THE DEFENDANT
ROBERT E. LEE, JR.
/s/ Michael S. Hillis
BY: ___________________________
MICHAEL S. HILLIS
DOMBROSKI HILLIS, LLC
129 Whitney Avenue
New Haven, CT 06510
mhillis@dkh-law.com
203-624-9096
Bar #: ct11867

Case 3:14-cr-00201-JAM Document 32 Filed 11/05/14 Page 3 of 3

CERTIFICATION
I hereby certify that on November 5, 2014 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 e-mail to all parties by operation of the Courts 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 Courts CM/ECF System.

/s/
Michael S. Hillis__ ___
MICHAEL S. HILLIS

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