Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00091-SLR

Document 75

Filed 03/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. CHRISTOPHER J. PHILLIPS, Defendant. : : : : : Cr. Action No.07-91-SLR : : : :

MOTION TO CONTINUE SENTENCING COMES NOW Defendant, CHRISTOPHER J. PHILLIPS, by and through counsel and moves this Honorable Court to continue sentencing in this matter, presently scheduled for April 16, 2008. In support of such motion, defendant asserts the following: 1. By order of the Court, counsel for defendant secured the

services of Dr. Alvin Turner to examine defendant in connection with this case. 2. The examination was performed on March 13, 2008. Dr.

Turner is in the process of preparing a report of his examination which defendant intends to submit to the Court in connection with sentencing. It is anticipated that the report will not be

completed until April 1, 2008. 3. The presentence office has indicated that it will need

additional time to review Dr. Turner's report and submit any comments regarding same. 4. AUSA Edmond Falgowski does not object to the requested

continuance.

Case 1:07-cr-00091-SLR

Document 75

Filed 03/25/2008

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WHEREFORE defendant prays that the Court continue sentencing for an additional two weeks beyond the presently scheduled date of April 16, 2008. Respectfully submitted,

/s/ Raymond M. Radulski Raymond M. Radulski Attorney for Defendant Christopher J. Phillips Date: March 25, 2008

Case 1:07-cr-00091-SLR

Document 75

Filed 03/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. CHRISTOPHER J. PHILLIPS, Defendant. : : : : : Cr. Action No.07-91-SLR : : : : ORDER IT IS ORDERED this _______ day of ___________, 2008 that sentencing is continued until _________________________________.

Hon. Sue L. Robinson

Case 1:07-cr-00091-SLR

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Filed 03/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. CHRISTOPHER J. PHILLIPS, Defendant. : : : : : Cr. Action No.07-91-SLR : : : :

CERTIFICATE OF SERVICE I hereby certify that on the date listed below, I

electronically filed Defendant Christopher J. Phillips' Motion to Continue Sentencing with the Clerk of Court using CM/ECF which will send notification of such filing to the following: AUSA Edmond Falgowski, 1007 Orange Street, 7th Floor, Wilmington, Delaware.

/s/ Raymond M. Radulski RAYMOND M. RADULSKI, ESQUIRE ID #332 Legal Arts Building, Suite 301 1225 North King Street Wilmington, DE 19801 (302) 658-9388 [email protected] Attorney for Defendant Christopher J. Phillips Dated: March 25, 2008