Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-mj-00102-MPT

Document 13

Filed 01/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. GERRI KNOTTS Defendant.

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Criminal Action No. 06-102M-MPT

MOTION FOR CONTINUANCE OF SENTENCING Defendant, Gerri Knotts, by and through her undersigned counsel, Eleni Kousoulis, hereby moves the Court for an order continuing the sentencing hearing in this case. In support of the motion, the defense submits as follows: 1. 2. Ms. Knotts is currently scheduled for sentencing on February 14, 2007 at 9:00 a.m. Additional time is needed in which to prepare the Presentence Report in this case.

In order to complete the Presentence Report, certain medical and psychological records pertaining to Ms. Knotts are needed and have not yet been received. probation in an effort to obtain the needed records. 3. 4. A thirty (30) day continuance of sentencing is respectfully requested. AUSA Dave Hall does not oppose this request for a continuance. The defense is working jointly with

Case 1:06-mj-00102-MPT

Document 13

Filed 01/04/2007

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WHEREFORE, the defense respectfully requests that the Court continue the sentencing hearing in this matter for 30 days. Respectfully Submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Gerri Knotts

DATED:

January 4, 2007

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Case 1:06-mj-00102-MPT

Document 13

Filed 01/04/2007

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

Criminal Action No. 06-102M-MPT

CERTIFICATE OF SERVICE The undersigned attorney for defendant Gerri Knotts hereby certifies that a copy of Defendant's Motion for Continuance of Sentencing is available for public viewing and downloading and was electronically delivered on January 4, 2007, to: Dave Hall, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

The undersigned attorney further certifies that on January 4, 2007, a copy of the attached Motion for Continuance of Sentencing was placed in a box in the United States District Court of the District of Delaware addressed to the following person: Martin Durkin U. S. Probation Officer Suite 400, 824 Market Street Wilmington, DE 19801-3588

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Gerri Knotts

Case 1:06-mj-00102-MPT

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Filed 01/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. GERRI KNOTTS, Defendant.

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Criminal Action No. 06-102M-MPT

ORDER In response to Ms. Gerri Knotts' Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ______day of _________________, 2007, that Defendant's sentencing hearing be re-scheduled for the ______ day of ________________, 2007 at __________ a.m./p.m.

The Honorable Mary Pat Thynge United States Magistrate Judge