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

Case 1:05-cr-00040-SLR

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Filed 06/30/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

TIMOTHY CANNON, Defendant.

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Criminal Action No. 05-40-SLR

MOTION TO EXTEND TIME TO FILE PRETRIAL MOTIONS Defendant Timothy Cannon, 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 pretrial motions may be filed. In support of this motion the Defendant submits as follows: 1. 2. Pre-trial motions for this case are due by June 30, 2005. Defense Counsel requires additional time to speak with Mr. Cannon to discuss how

the defense is going to proceed in this case. Defense counsel also needs additional time to conduct investigation in this case before it can be determined which pre-trial motions, if any, need to be filed. For these reasons, the defense respectfully requests additional time in which to file any pre-trial motions. 3. Richard Andrews, Esquire, the attorney handling the case for the government, does

not object to the enlargement of time. 4. The parties have agreed that any additional time given in which to file pre-trial

Case 1:05-cr-00040-SLR

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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 to any time after July 29, 2005.

Respectfully Submitted,

/s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender First Federal Plaza 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Timothy Cannon

Dated: June 30, 2005

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Case 1:05-cr-00040-SLR

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CERTIFICATE OF SERVICE Undersigned counsel certifies that a copy of Defendant's Motion to Extend Time to File Pretrial Motions is available for public viewing and downloading and was electronically delivered on June 30, 2005, to: Richard Andrews, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

/s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street Suite 110 Wilmington, DE 19801 (302) 573-6010

DATED: June 30, 2005