Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1:06-cr-00050-GMS

Document 209

Filed 10/12/2007

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. WILLIE BROWN, Defendant. ) ) ) ) ) ) ) ) )

Criminal Action No. 06-50-1 GMS

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant Willie Brown, by and through his undersigned counsel, hereby moves this Honorable Court, pursuant to Federal Rule of Criminal Procedure 45(b) and Local Rule 5(a), for an order enlarging the time within which pretrial motions may be filed and heard. In support thereof, Mr. Brown presents the following: 1. Pursuant to the Court's October 10, 2007 Scheduling Order, pretrial

motions are to be filed today, Friday, October 12, 2007. Due primarily to his Superior Court caseload, Defense Counsel is not adequately prepared to file pre-trial motions at the present date. Thus, Counsel requests that this Court allow an enlargement of time for the filing of pre-trial motions. Counsel requests that the time period be extended 5 business days to Friday, October 19, 2007. 2. As this enlargement of time is sought in the interest of justice, the time between

October 12, 2007 and October 19, 2007 should be excluded from the time period set forth in U.S.C. 18 § 3161(c) (1). 3. Defense Counsel has spoken to AUSA Douglas McCann who does not oppose this

Case 1:06-cr-00050-GMS

Document 209

Filed 10/12/2007

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request. WHEREFORE, Defendant Brown respectfully requests that this Honorable Court enter an Order extending the time period for Defendant to file pre-trial motions 5 business days to October 19, 2007.

JAN A. T. VAN AMERONGEN, LLC

/s/ Jan A. T. van Amerongen, Jr. Jan A. T. van Amerongen, Jr. (#3453) Legal Arts Building 1225 King Street, Suite 301 Wilmington, Delaware 19801 Telephone: (302) 656-8007 Attorney for Defendant Willie Brown

DATED: October 12, 2007

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Case 1:06-cr-00050-GMS

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CERTIFICATE OF SERVICE The undersigned attorney for Defendant hereby certifies that on October 12, 2007, the attached Unopposed Motion to Enlarge Time was served via CM/ECF electronic filing to counsel of record.

/s/ Jan A. T. van Amerongen, Jr. Jan A. T. van Amerongen, Jr. (#3453) Legal Arts Building 1225 King Street, Suite 301 Wilmington, Delaware 19801 Telephone: (302) 656-8007 Attorney for Defendant Willie Brown

Case 1:06-cr-00050-GMS

Document 209

Filed 10/12/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. WILLIE BROWN, Defendant. ) ) ) ) ) ) ) ) )

Criminal Action No. 06-50-1 GMS

ORDER In response to Defendant's Unopposed Motion for Enlargement of Time to file pre-trial motions, this Court hereby ORDERS on this ________ day of October, 2007, that Defendant's pretrial motions are due on October 19, 2007.

_____________________________ The Honorable Gregory M. Sleet