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

I I 1 I I Case 106-cr-00095-JJF { if i I Filed 03/17/2006 Page 1 of 3 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AIVIERICA, :
Plaintiff,
v. Criminal Case N0. 05-95-JJF
1 MACDONALD P. TAYLOR
A Defendant. i
JOINT MOTION TO ENLARGE THE TIME FOR FILING PRE—TRIAL MOTIONS
AND TO WAIVE APPLICATION OF THE SPEEDY TRIAL ACT AND REQUEST FOR
STATUS CONFERENCE
NOW COMES the United States of America, by its attorneys, Colm F. Connolly, United
States Attorney for the District of Delaware, and Shannon Thee Hanson, Assistant United States
Attorney, together with Christopher Koyste, Esq., counsel for defendant MacDonald P. Taylor, 9
and respectfully moves the Court to issue an order that enlarges the time period for the filing of
A pretrial motions to May 19, 2006, and excludes this time period from the Speedy Trial Act I
calculations, pursuant to 18 U.S.C. § 3161(h)(8)(A). The parties further request a status `
Q conference in this matter no earlier than April 11, 2006. In support of this motion, the parties
aver as follows:
1. On October 25, 2005, defendant MacDonald Taylor was indicted on various Hand
charges. On November 29, 2005, Mr. Taylor had his initial appearance and arraignment and was
released on conditions pending trial.
2. On January 19, 2006, the defendant filed a motion to enlarge the time for tiling
1 pretrial motions, which was granted by the Court on January 20, 2006. Accordingly, pretrial
I motions are due in this case on or before March 19, 2006. i

Case 1 :05-cr-00095-JJF Document 12 Filed 03/17/2006 Page 2 of 3
3. The government is contemplating bringing a superseding indictment against the
defendant on March 28, 2006, but is awaiting the final results of the FBI’s investigation.
4. Accordingly, the parties request that the Court schedule a status conference in this p
matter no earlier than April ll, 2006, two weeks after the proposed superseding indictment. The
‘ parties further request that the motions deadline be extended an additional sixty (60) days, until
May 19, 2006. Finally, the parties move for the exclusion of this sixty (60) day time period from
` the calculations ofthe Speedy Trial Act, 18 U.S.C. Section 3 l6l(c)(l), and assert that such a .
time exclusion is in the interests of j ustice. Because Mr. Taylor is not in custody, the parties l
contemplate no prejudice to him as a result of this request, and further contemplate, in light of
the proposed additional charges, that the needs of justice will best be served by an extension of _
the motions deadline.
5. WHEREFORE, the parties respectfully request the Court to issue an order
scheduling a status conference no earlier April 1 1, 2006, enlarging the time period for the filing 1
of pre-trial motions to May 19, 2006, and excluding this additional sixty (60) days from the
Speedy Trial Act calculations, pursuant to 18 U.S.C. § 3l6l(h)(8)(A). A proposed Order is
attached.
Respectfully submitted,
( COLM F. CONNOLLY I
United Statg-‘At·to§ney= I
BY: nl dilii ·- Q/""-—~....
Christopher . Koyste, Esq. on T ee anson
Counsel for MacDonald Taylo ssistant United States Attorney
Dated: March 17, 2006 _ I
-2- · .

Case 1 :05-cr-00095-JJF Document 12 Filed 03/17/2006 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, : _
Plaintiff, l _ p
v. Criminal Case N0. 05-95-JJF I
MACDONALD P. TAYLOR
Defendant.
O R D E R
Having considered the parties’ Joint Motion to Enlarge the Time for Filing Pre-trial
i Motions and to Waive Application of the Speedy Trial Act and Request for Status Conference,
IT IS HEREBY ORDERED this _ day of March, 2006, that the foregoing Motion is
GRANTED.
(1) Pre-trial motions are to be filed on or before May 19, 2006. This additional time
period is hereby excluded from the Speedy Trial Act calculations in the interests of justice for the
reasons set forth in the parties’ Motion.
· (2) A status conferencein this matter is set for April ____, 2006 at _____.
·
Z United States District Judge