Free Motion to Continue - District Court of Delaware - Delaware

Case 1 :06-cr-00040-JJF Document 1 1 Filed 08/30/2006 Page 1 of 4
` IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
I - Plaintiff, j
v. j Criminal Action No. 06-40-J JF
- DONNA C. FISHER, j -
Defendant. __ j `
JOINT MOTION TO CONTINUE SENTENCING HEARING DATE
NOW COMES the United States of America, by and through its undersigned attorneys,
and represents the following:
1. The Court has set a Sentencing Hearing in this matter for September 12, 2006 at 12:30
p.m. _ _
2. Undersigned counsel has a trial in another case scheduled before Judge Sleet on the
date of the Sentencing Hearing in this matter. Undersigned counsel has spoken with the
l defendant’s counsel, Samuel Rosenthal, Esq., who stated that he also had a case-related conflict
with the Sentencing Hearing in this matter. I
3. As a result, the Government and the defendant jointly move that the Court continue
the Sentencing Hearing in this matter to another upcoming date that is convenient for the Court. _
The Government and the defendant are jointly available on the following dates in the next few
weeks: September 18 (all times other than 11:00 a.m. — 12:00 p.m.), September 19, September
22, September 28-29, October 2-3, October 10, October 11 (all times other than 4:30 - 6:00 8

Case 1 :06-cr-00040-JJF Document 11 Filed 08/30/2006 Page 2 of 4
pm.), October 12 (all times other than 10:00 — 11:00 am.), October 13, October 16-18, October
19 (all times other than 9:00 - 10:00 a.m.) and October 20.
4, Defendant’s counsel has authorized the Government to file this motion on behalf of
both parties. n
WHEREFORE, the United States and the defendant jointly request that the Court
continue the Sentencing Hearing date and scheduled a new hearing date at the Court’s
convenience. G
Respectiitlly submitted,
COLM F. CONNOLLY
UNITED STATES ATTORNEY
_ BY: /s/
A - ‘ Christopher J. Burke
Assistant United States Attorney
Dated: August 30, 2006
2

- Case 1 :06—cr#00040—JJF Document 11 Filed 08/30/2006 Page 3 of 4
· IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
A UNITED STATES OF AMERICA, )
· )
Plaintiff, )
)
v. » ) Criminal Action No. 06-40-J J F
)
DONNA C. FISHER, )
)
_ Defendant. )
ORDER
AND NOW this _ day of , 2006, it is hereby ordered that the parties’
Joint Motion to Continue Sentencing Hearing Date be GRANTED, and that the Sentencing
I C Hearing in this matter shall now be set for , 2006 at .
Honorable Joseph J. Farnan, Jr.
United States District Judge
3 l -

Case 1 :06-cr-00040-JJF Document 11 Filed 08/30/2006 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE .
UNITED STATES OF AMERICA, )
)
Plaintiff )
)
v. ) Criminal Action No. 06-40-JJF
‘ )
DONNA C. FISHER, )
)
_ Defendant. )
I CERTIFICATE OF SERVICE
I, Christopher J. Burke, Assistant United States Attorney for the District of Delaware,
hereby certify that on the 30th day of August, 2006, I caused to be electronically tiled a Joint
Motion to Continue Sentencing Hearing Date with the Clerk ofthe Court using CM/ECF.
Said document is available for viewing and downloading from CM/ECF. I further certify that a
copy of the foregoing was sent via U.S. mail to counsel of record as follows:
Samuel Rosenthal, Esq. U F
Curtis, Mallet—Prevost, Colt & Mosle LLP
1200 New Hampshire Ave, N.W.
Suite # 403
_ Washington, DC 20036-6808 _
/s/
. _ ‘ . Christopher .I. Burke
Assistant United States Attorney .
_ 4