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

Case 1 :06-cr—OOO31—JJF Document 32-2 Filed 06/O2/2006 Page 1 g[__4___
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA :
v. : CRIMINAL NO. 06-31-JJF
SALVADOR MARTINEZ-TORRES :
MOTION FOR EXTENSION OF TIME FOR FILING OF PRETRIAL MOTIONS
Defendant, Salvador Martinez-Torres by his undersigned counsel, Ubel G. Velez., Esquire, ·
and pursuant to Fed.R.Crim.Pro. 45(b)(1)(A), hereby MOVES that this Honorable Court
GRANT him an extension for the filing of pretrial motions, and avers the following in support
thereof?
1. Defendant Salvador Martinez Torres is charged in this matter by Indictment tiled on
March 28, 2006 with the violation ofthe following statutes: 21 U.S.C. § 841 (a)( 1) and (b)(l)(A)
(conspiracy to distribute cocaine).
2. The indictment also charged Francisco Barrera-Lopez and Jose Luis Becerra Yepcz.
3. Undersigned counsel was appointed to represent Defendant pursuant to the Criminal
Justice Act, 18 U.S.C. § 3006e.
4. The court granted Defendant up to June 2, 2006 to file pre-trial motions.
5. Defendant had received a plea offer, which was revoked on June I, 2006 since one if
the defendants in this case intends to proceed to trial.
6. Given the extremely short period of time that has elapsed from the revocation of the
plea offer, and the due date for filing of pretrial Motions, Defense Counsel requires additional
UBEL G. VELEZ LAW OFFICE
24 Wilmont Mews, West Chester, PA 19382
(610) 431-0809

Case 1:06-cr—OOO31—JJF Document 32-2 Filed 06/O2/2006 Page 2 of 4
time to prepare the case.
7. This is the first request for an Extension of Time in this matter, and Defense Counsel
understands is the last one.
8. Counsel for the Govermnent does not oppose this Motion.
9. Now that the plea offer is revoked, it is essential for the defense to determine the
course of action to follow in this case before Pre-trial Motions are tiled, and a reasonable period
of time to tile said motions is required.
Accordingly, defendant Salvador Martinez Torres respect ii1lly requests that this
Honorable Court EXTEND the time for the filing of Pretrial Motions in this matter, for a period I
of forty five (45) days.
Respectfully submitted,
s. Ubel G. Velez
Esquire `
Attorney for Salvador Martinez-Torres
UBEL G. VELEZ LAW OFFICE
24 Wilmont Mews, West Chester, PA 19382
(610) 431-0809

Case 1:06-cr—OOO31—JJF Document 32-2 Filed 06/O2/2006 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA 1
v. : CRIMINAL NO. 06-31-JJF
SALVADOR MARTINEZ-TORRES :
ORDER
t .
AND NOW, this day of , 2006, in consideration of
Defendant Salvador Martinez-Torres’ Motion for Extension of Time for filing of Pretrial Motions,
it is hereby ORDERED that said Motion is GRANTED, and Pretrial Motions in this matter must
now be filed on or before .
l
_ TI-IE COURT:
i
il
HONORABLE JOSEPH J. FARNAN, JR.
UBEL G. VELEZ LAW OFFICE
24 Wilmont Mews, West Chester, PA 19382
(610) 431-0809

Case 1:06-cr—OOO31—JJF Document 32-2 Filed 06/O2/2006 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA :
v. : CRIMINAL NO. 06—3l-JJF
SALVADOR MARTINEZ-TORRES 1
CERTIFICATE OF SERVICE
I, Ubel G. Velez, Esquire, do hereby certify that this 2“" day of June, 2006, I did serve
true and correct copies ofthe within Motion for Extension of Time for Filing of Pretrial Motions
by electronic means to the Assistant United States Attomey assigned to this case, and all others
defense counsel.
. s. Ubel G. Velez
Ubel G. Velez, Esquire
Attomey for Salvador Martinez-Torres
UBEL G. VELEZ LAW OFFICE
24 Wilmcnt Mews, West Chester, PA 19382
(610) 431-0809