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

Case 1:05-cr-00095-JJF

Document 10

Filed 01/19/2006

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA Plaintiff, v. MACDONALD 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 P. Taylor, by and through his undersigned counsel, Christopher S. Koyste, hereby moves the Court to issue an order that enlarges the time period for the filing of pretrial motions to March 19, 2006 and excludes this time period from the Speedy Trial Act calculations. This additional period of time will allow the Defense sufficient time to review discovery, investigate the allegations in this action, and negotiate with the Government. Counsel submits the following in support thereof: 1. Mr. Taylor was indicted on October 25, 2005 for 8 counts of fraud involving mortgage applications, bankruptcy filings and misuse of social security numbers. Discovery is voluminous in this action and was received on January 9, 2006. Mr. Taylor requires additional time 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 to March 19, 2006. Mr. Taylor also moves for the exclusion of this additional time period from the calculations of the Speedy Trial Act, 18 U.S.C. Section 3161(c)(1), and asserts that such a time exclusion in the interests of justice. 2. AUSA Shannon Hanson does not oppose Mr. Taylor's request.

Case 1:05-cr-00095-JJF

Document 10

Filed 01/19/2006

Page 2 of 3

WHEREFORE, Mr. Taylor respectfully requests the Court to issue an order that enlarges the time period for the filing of pre-trial motions to March 19, 2006 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: January 19, 2006

Case 1:05-cr-00095-JJF

Document 10

Filed 01/19/2006

Page 3 of 3

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 January 19, 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 P. Taylor