Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00029-GMS

Document 12

Filed 08/15/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. KELIN BRADLEY, Defendant. : : : : : : : : :

Criminal Action No. 07-29-GMS

MOTION TO RESCHEDULE CHANGE OF PLEA HEARING Christopher S. Koyste, on behalf of Kelin Bradley, hereby moves this Honorable Court to reschedule the date for Mr. Bradley's Change of Plea Hearing from September 5, 2007 at 9:30 a.m. to September 18, 2007 at 2:00 p.m. 1. Counsel is scheduled to appear in an Attempted Murder trial in the Superior Court in and For New Castle County which begins the morning of September 5, 2007. Counsel spoke to AUSA Robert F. Kravetz and he does not oppose Mr. Bradley's request to reschedule the date for his Change of Plea Hearing so as to not conflict with the noted trial date. 2. Counsel informed Your Honor's staff of this situation and was told that September 18, 2007 at 2:00 p.m. would be an available date and time to hold the Change of Plea Hearing. AUSA Kravetz has no opposition to this new date and time.

Case 1:07-cr-00029-GMS

Document 12

Filed 08/15/2007

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WHEREFORE, Mr. Bradley respectfully requests Your Honor to reschedule the date for the Change of Plea Hearing to September 18, 2007 at 2:00 p.m.

Respectfully submitted,

/s/ Christopher S. Koyste Christopher S. Koyste, Esquire 800 North King Street, Suite 302 Wilmington, Delaware 19801 (302) 419-6529 Email: [email protected] Attorney for Kelin Bradley DATED: August 15, 2007

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Case 1:07-cr-00029-GMS

Document 12

Filed 08/15/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. KELIN BRADLEY, Defendant. : : : : : : : : :

Criminal Action No. 07-29-GMS

CERTIFICATE OF SERVICE Undersigned Counsel certifies that the attached filing of Kelin Bradley is available for public viewing and downloading and was electronically delivered on August 15, 2007 to:

Robert F. Kravetz, Esquire Assistant United States Attorney United States Attorney's Office 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ Christopher S. Koyste Christopher S. Koyste, Esquire 800 North King Street, Suite 302 Wilmington, Delaware 19801 (302) 419-6529 Email: [email protected] Attorney for Kelin Bradley

Case 1:07-cr-00029-GMS

Document 12

Filed 08/15/2007

Page 4 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. KELIN BRADLEY, Defendant. : : : : : : : : :

Criminal Action No. 07-29-GMS

ORDER

AND NOW, this _____ Day of ____________, 2007, upon consideration of Defendant's Motion to Reschedule Change of Plea Hearing, it is hereby ORDERED that Defendant, Kelin Bradley's Change of Plea Hearing is rescheduled to September 18, 2007 at 2:00 p.m.

_____________________________ Chief Judge Gregory M. Sleet United States District Court