Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1:07-cr-00036-GMS

Document 12

Filed 06/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY RODRIGUEZ, Defendant.

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Criminal Action No. 07-36-GMS

MOTION TO EXTEND TIME TO FILE PRE-TRIAL MOTIONS Defendant, Anthony Rodriguez, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court pursuant to Federal Rule of Criminal Procedure 45(b) and Local Rule 5(a) for an Order enlarging the time within which pre-trial motions may be filed. In support of this motion the Defendant submits as follows: 1. 2. Pre-trial motions in this case are due by June 8, 2007. Defense counsel needs additional time to conduct investigation in this case to

determine what, if any, pre-trial motions should be filed. The investigation defense counsel is conducting will not be completed by the current June 8, 2007 motions deadline. 3. The defense respectfully requests an extension of time of 30 days in which to

file any pre-trial motions. 4. AUSA Edmond Falgowski, counsel for the government, has no objection to

defendant's motion for an extension of time in which to file pre-trial motions, making the motion unopposed.

Case 1:07-cr-00036-GMS

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Filed 06/07/2007

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5.

The parties have agreed that any additional time given in which to file pre-trial

motions will be excludable under the Speedy Trial Act. WHEREFORE, it is respectfully requested that the time for Defendant to file pre-trial motions be extended until anytime after July 9, 2007.

Respectfully Submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Anthony Rodriguez

Dated: June 7, 2007

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Case 1:07-cr-00036-GMS

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Filed 06/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY RODRIGUEZ, Defendant.

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Criminal Action No. 07-36-GMS

ORDER Having considered Defendant's Motion to Extend Time to File Pre-trial Motions, IT IS HEREBY ORDERED this day of day of , 2007, that Defendant , 2007.

Rodriguez' pre-trial motions shall be due on the

Honorable Gregory M. Sleet United States District Court