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

Case 1:07—cr—00098-SLR Document 15 Filed 10/11/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
) Criminal Action No. 07-98-SLR
)
v. )
)
)
CARL W. WILSON, JR., )
)
Defendant. )
MOTION FOR EXTENSION OF TIME TO FILE PRE-TRIAL MOTIONS
According to the Court’s Scheduling Order, pre—trial motions in the above referenced
case are due on October 19, 2007.
On August 29, 2007, Defense counsel entered his appearance through a substitution of
counsel. Discovery has been requested and the Government has provided discovery in response
thereto. The receipt and review of some discovery, such as the images, needs to be completed
and pre-trial motions are due on October 19, 2007. The discovery needs to be viewed prior to
the tiling of any pre-trial motions. Moreover, the Government has made an offer in this case,
which needs to be evaluated and discussed with Mr. Wilson prior to determining whether there
are appropriate pre—trial motions. Mr. Wilson is currently incarcerated in New Jersey. The
Government has no objection to an extension of the deadline to tile pre-trial motions. An
extension will enable counsel to have the Defendant transported to the Federal Building to view
the discovery and that can not be accomplished prior to October 19, 2007. An evaluation of the
evidence and plea offer may, if accepted, obviate the need for pre-trial motions.

Case 1:07—cr—00098-SLR Document 15 Filed 10/11/2007 Page 2 of 2
WHEREFORE, Defendant respectfully requests that of the deadline to tile pre-trial
motions be extended to November 19, 2007.
Dated: October 11, 2007
RICHARD R. WIER, JR., P.A.
/s/Richard R. Wier, Jr.
Richard R. Wier, Jr. (#716)
Two Mill Road, Suite 200
Wilmington, DE 19806
(302) 888-3222

Case 1:07-cr—00098-SLR Document 15-2 Filed 10/11/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
) Criminal Action No. 07-98-SLR
)
v. )
)
)
CARL W. WILSON, JR., )
)
Defendant. )
ORDER
AND NOW, this day of , 2007, upon consideration of
Defendant Carl Wi1son’s Motion for Extension of Time to File Pre—Trial Motions, it is hereby
ORDERED that Defendant’s Motion is GRANTED.
IT IS SO ORDERED
THE HONORABLE SUE L. ROBINSON