Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00136-GMS

Document 23

Filed 06/12/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL T. JACKSON, Defendant.

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Criminal Action No. 06-136-GMS

DEFENDANT'S UNOPPOSED MOTION FOR CONTINUANCE OF SENTENCING HEARING Defendant, Michael T. Jackson, by and through his undersigned counsel, Edson A. Bostic, hereby moves the Court for an Order continuing the Sentencing Hearing in this case. In support of this motion, Mr. Jackson submits as follows: 1. On or about March 22, 2007, Mr. Jackson appeared before this Court and plead guilty

to one count of being a felon in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). Sentencing is currently set for June 27, 2007. 2. The matter was assigned to Christopher S. Koyste, Assistant Federal Public Defender,

as trial counsel. 3. On June 1, 2007, Mr. Koyste resigned from the Federal Public Defender's Office. As

such, Edson A. Bostic, Federal Public Defender, assumed the case as trial counsel. 4. Because of the reassignment, Mr. Bostic requires additional time to meet with Mr.

Jackson and familiarize himself with the case to prepare for sentencing. Additionally, Mr. Bostic also requires additional time to review the Presentence Report with Mr. Bostic and make comments and

Case 1:06-cr-00136-GMS

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objections, if necessary. 5. Accordingly, Mr. Jackson believes that, in the interests of justice, a continuance of the

Sentencing Hearing is warranted. 6. Robert F. Kravetz, Assistant United States Attorney, counsel for the government, does

not oppose this request. WHEREFORE, it is respectfully requested that this Court issue an Order continuing the Sentencing Hearing in this case for three (3) weeks.

Respectfully Submitted,

/s/ Edson A. Bostic Federal Public Defender Attorney for Defendant Michael T. Jackson One Customs House 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected]

Dated: June 12, 2007

Case 1:06-cr-00136-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL T. JACKSON, Defendant.

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Criminal Action No. 06-136-GMS

ORDER Having considered Defendant's Unopposed Motion For Continuance Of Sentencing Hearing; IT IS HEREBY ORDERED this Defendant Jackson's Sentencing Hearing shall be on the a.m./p.m. day of day of , 2007, that , 2007, at _____

Honorable Gregory M. Sleet United States District Court