Free Motion to Continue - District Court of Delaware - Delaware

Case 1 :06-cr-00125-SLR Document 21 Filed O3/08/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT O
FOR THE DISTRICT OF DELAWARE I
_ UNITED STATES OF AMERICA, :
Plaintiff ‘ l
v. Criminal Action_No. 06-1255SLR
n - TERESA M. FLOOD,
. A Defendant.
MOTION FOR CONTINUAN CE
i I NOW COMES the United States of America, by and through its undersigned counsel,
n Colm F. Connolly, United States Attorney for the District of Delaware, and Beth Moskow-
I Schnoll, Assistant U.S. Attorney, and, for the following reasons, respectfully requests a three
I week continuance of the evidentiary hearing currently scheduled for March 12, 2007:
_ 1. On November 16, 2006, the defendant was charged in a three count indictment
I with bank fraud in violation of 18 U.S.C. § 1344, with aggravated identity theft in violation of 18
l U U.S.C. § 1028A, and with wire fraud in violation of 18 U.S.C. § 1343. The defendant was E
` · I released on bail at her initial appearance and has remained on pretrial release. I ?
2. The defendant frled pretrial motions, and an evidentiary hearing is scheduled
. for March 12, 2007, at 4:30 p.m. However, the parties are moving towards a non—trial resolution A
· of the case, and a three week continuance of the evidentiary hearing could give the parties the 1
l _ additional time needed to resolve this matter.
I 3. Richard Freeman, Esq., counsel for the defendant, does not oppose this request.

I Case 1:O6—cr—OO125-SLR Document 21 Filed O3/08/2007 Page 2 of 4
A Wl-IEREFORE, the United States respectfully requests that the Court continue the _
evidentiary hearing for three weeks or to a date and time consistent with the Court’s calendar.
n COLM F. CONNOLLY
. Unit States Attorney
»~ /MMM/t»
· Beth M0 skew-Schnoll
2 __ t Assistant United States Attorney _
Z Dated: March 7, 2007

I Case 1:O6—cr—OO125-SLR Document 21 Filed O3/08/2007 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action No. 06-125-SLR `
TERESA M. FLOOD,
Defendant.
ORDER
AND NOW, this _ day of , 2007, upon consideration of the
defendant’s Motion for Continuance, it is hereby ORDERED that the evidentiary hearing _
previously scheduled for March 12, 2007, at 4:30 pm. is continued to
T . W .
Chief U.S. District Judge

- I Case 1:06-cr-00125-SLR Document 2t Filed O3/08/2007 Page 4 of 4 .
g CERTIFICATE OF SERVICE i
i I UNITED STATES OF AMERICA ) · i _
. v. _ ) Criminal Action No. 06-125-SLR
A ` · )
0 TERESA M. FLOOD )
i I, Sharon Bernardo, an employee ofthe United States Attorney’s Office, hereby certify that on
i March 8, 2007, I electronically filed the foregoing: _ I ‘
_ g _ MOTION FOR CONTINUANCE
with the Clerk of the Court using the CM/ECF which will send notification of such filing to:
_ ` i Richard G. Freernan, Esquire I i i i i
. [email protected] g .