Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00101-JJF

Document 26

Filed 02/27/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA Plaintiff, v. JAMES A. BALL, III, Defendant. : : : : : : : : :

Criminal Action No. 06-101-JJF

MOTION FOR CONTINUANCE OF SCHEDULING CONFERENCE Defendant, James Ball, by and through his undersigned counsel, Christopher S. Koyste, hereby moves the Court for an order continuing the March 1, 2007 scheduling conference, which has been set to take place at 10:30 a.m. Counsel submits the following in support thereof: 1. Mr. Ball has been charged with committing wife fraud in violation of 18 U.S.C. Section 1343 and money laundering in violation of 18 U.S.C. Sections 1956(a)(1)B)(i) and 2. Mr. Ball is currently released on bail and being supervised by pre-trial services. The parties have made progress to resolve this action and need to finalize the negotiations. 2. The Court scheduled a sentencing conference on March 1, 2007 at 10:30 a.m. Unfortunately, Defense Council has a change of plea hearing scheduled at that time before Chief Judge Susan L. Robinson. Therefore, the Defense requested a continuance in order to reschedule the scheduling conference. Council spoke to David Weiss, in place of Beth Moskow-Schnoll who indicated that his office does not oppose this request.

Case 1:06-cr-00101-JJF

Document 26

Filed 02/27/2007

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WHEREFORE, Mr. Ball respectfully requests the Court to continue the scheduling conference to a date and time in the future.

/s/ CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 302-573-6010 [email protected] Attorney for James A. Ball, III

DATED: February 27, 2007

Case 1:06-cr-00101-JJF

Document 26

Filed 02/27/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA Plaintiff, v. JAMES A. BALL, III, Defendant. : : : : : : : : :

Criminal Action No. 06-101-JJF

ORDER In response to the Defense's Motion For Continuance, it is hereby ORDERED this ______ day of _______________, 2007, that Defendant Ball's scheduling conference is continued to a date to be determined in the future.

_____________________________ Joseph J. Farnan, Jr. United States District Court Judge

Case 1:06-cr-00101-JJF

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Filed 02/27/2007

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CERTIFICATE OF SERVICE Undersigned counsel certifies that his Motion for Continuance is available for public viewing and downloading and was electronically delivered on February 27, 2007 to:

David Weiss, Esq. Assistant United States Attorney 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 302-573-6010 [email protected] Attorney for James A. Ball, III