Free Motion for Waiver of Speedy Trial Act - District Court of Delaware - Delaware

Case 1:05-cr-00095-JJF

Document 18

Filed 05/24/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA Plaintiff, v. MCDONALD P. TAYLOR, Defendant. ) ) ) ) ) ) ) ) )

Criminal Action No. 05-095-JJF

MOTION TO ENLARGE THE TIME FOR THE FILING OF PRE-TRIAL MOTIONS AND TO WAIVE THE APPLICATION OF THE SPEEDY TRIAL ACT

Defendant, MacDonald Taylor, by and through his undersigned counsel, Christopher S. Koyste, hereby moves the Court to issue an order to issue an order that enlarges the time period for the filing of pre-trial motions by 60 days and excludes this time period from the Speedy Trial Act calculations. This 60 day time period will allow the Defense additional time to review discovery, investigate the allegations in this action, and negotiate with the Government. Counsel submits the following in support thereof: 1. A superseding indictment was rendered against Mr. Taylor on March 28, 2006 for 10 counts of fraud involving mortgage applications, bankruptcy filing and misuse of social security numbers. Pre-trial motions are due on May 19, 2006. 2. Discovery is voluminous in this action and Mr. Taylor needs an additional 60 days to review discovery, investigate the allegations in this action, and negotiate with the Government. Mr. Taylor moves to enlarge the time period for the filing of pre-trial motions 60 days, making pre-trial motions due no later than July 18, 2006. Mr. Taylor also moves for the exclusion of 60 days as calculated by the Speedy Trial Act, 18 U.S.C. Section 3161(c)(1), and asserts that such a time

Case 1:05-cr-00095-JJF

Document 18

Filed 05/24/2006

Page 2 of 3

exclusion in the interests of justice. 3. AUSA Shannon does not oppose Mr. Taylors' request for an enlargement of time and the waiver of the Speedy Trial calendar. WHEREFORE, Mr. Taylor respectfully requests the Court to issue an order that enlarges the time period for the filing of pre-trial motions by 60 days and excludes this time period from the Speedy Trial Act calculations.

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for MacDonald Taylor Dated: May 24, 2006

Case 1:05-cr-00095-JJF

Document 18

Filed 05/24/2006

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CERTIFICATE OF SERVICE Undersigned counsel certifies that this Motion to Enlarge the Time for the Filing of Pre-Trial Motions and Waive the Application of the Speedy Trial Act is available for public viewing and downloading and was electronically delivered on May 24, 2006 to:

Shannon Hanson, Esq. Assistant United States Attorney 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for MacDonald Taylor