Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cr-00104-JJF

Document 18

Filed 04/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

LEONARD GARNER, Defendant.

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Criminal Action No. 05-104-JJF

MOTION FOR CONTINUANCE OF CHANGE OF PLEA HEARING Defendant, Leonard Garner, by and through his undersigned counsel, Eleni Kousoulis, hereby moves this Court for an order re-scheduling the change of plea hearing in this case. In support of the motion, the defense submits as follows: 1. A change of plea hearing is currently scheduled in the above-captioned matter for

April 24, 2006, at 11:00 a.m. 2. Due to a personal conflict, defense counsel will not be available on April 24, 2006,

and respectfully requests that the change of plea hearing be re-scheduled to another day. 3. Assistant U.S. Attorney Richard Andrews informed defense counsel that the

government has no objection to the defense request for a continuance. 4. Defense counsel was informed by Your Honor's chambers that the Court has time

available on April 28, 2006 at 1:00 p.m. in which to conduct this change of plea hearing and respectfully requests that Mr. Garner's change of plea hearing be re-scheduled for that date and time.

Case 1:05-cr-00104-JJF

Document 18

Filed 04/20/2006

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5.

The defense agrees to waive any time, pursuant to the Speedy Trial Act, between now

and the date of the re-scheduled hearing. WHEREFORE, for these reasons and any other such reasons as shall appear to the Court, the defense respectfully requests that the Court re-schedule the change of plea hearing in this case to April 28, 2006 at 1:00 p.m.

Respectfully Submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender First Federal Plaza 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Leonard Garner

Dated: April 20, 2006

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Case 1:05-cr-00104-JJF

Document 18

Filed 04/20/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

LEONARD GARNER, Defendant.

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Criminal Action No. 05-104-JJF

CERTIFICATE OF SERVICE Undersigned counsel certifies that a copy of Defendant's Motion for Continuance of Change of Plea Hearing is available for public viewing and downloading and was electronically delivered on April 20, 2006, to: Beth Moskow-Schnoll, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King St., Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Leonard Garner