Free Motion to Continue - District Court of Delaware - Delaware

Case 1:08-cr-00026-GMS

Document 10

Filed 05/05/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. MICHELLE LYNCH, Defendant.

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Criminal Action No. 08-26-GMS

MOTION FOR CONTINUANCE OF SENTENCING Defendant, Michele Lynch, by and through his undersigned counsel, Keir Bradford, hereby moves the Court for an Order continuing the sentencing hearing in this case. In support of the motion, the defense submits as follows: 1. 2. Ms. Lynch is currently scheduled for sentencing on June 5, 2008 at 4:15p.m. Defense counsel has arranged for Dr. Catherine Barber, Ph. D. to conduct a forensic

evaluation of Ms. Lynch on May 15, 2008. 3. Additionally, United States Probation Officer, Jean Lubinski, has modified Ms. Lynch's

pre-trial conditions to include mental health counseling, with Dr. Carlena Tucker-Okine Ph D. Ms. Lynch is due to begin counseling sessions with Dr. Tucker-Okine soon after the evaluation.

Case 1:08-cr-00026-GMS

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Filed 05/05/2008

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4.

Defense counsel respectfully requests that Ms. Lynchs' sentencing be continued for

an additional thirty (30) days to allow Dr. Barber time to submit a report, also to allow Ms. Lynch an opportunity to address any treatment issues, which may be helpful for sentencing. 5. Assistant United States Attorney, David L. Hall, the attorney handling this case for

the government, has no objection to the defense's continuance request. WHEREFORE, the defendant respectfully requests that the Court continue the sentencing hearing in this matter to anytime after July 5, 2008.

Respectfully Submitted,

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

DATED: May 5, 2008

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Case 1:08-cr-00026-GMS

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Filed 05/05/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. MICHELLE LYNCH, Defendant.

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Criminal Action No. 08-26-GMS

ORDER In response to Ms. Lynch's Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ________ day of ____________________, 2008, that Defendant's sentencing hearing be re-scheduled for the _______ day of _________________, 2008 at ________ a.m./p.m.

The Honorable Gregory M. Sleet Chief Judge, United States District Court