Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cr-00039-GMS

Document 25

Filed 05/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

JEFFREY BENTLEY, Defendant.

: : : : : : : : : :

Criminal Action No. 05-39-GMS

MOTION FOR CONTINUANCE OF SENTENCING Defendant, Jeffrey Bentley, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court for an order continuing the sentencing hearing in this case. In support of the motion, the defense submits as follows: 1. 2. Mr. Bentley is currently scheduled for sentencing on May 25, 2006 at 11:00 a.m. Defense counsel requires additional time to prepare for sentencing and additional

time to review the presentence report with Mr. Bentley to determine what, if any, objections to the presentence report the defense wishes to make. 3. Defense counsel respectfully requests that Mr. Bentley's sentencing be continued to

allow defense counsel time to adequately prepare for sentencing in light of some of the information contained in the presentence report. 4. a continuance. AUSA Edmund Falgowski and USPO Margaret Bray do not oppose this request for

Case 1:05-cr-00039-GMS

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Filed 05/18/2006

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5.

Defense counsel will be out of the office from May 30, 2006 through June 2, 2006,

and also from June 21, 2006 through June 27, 2006. It is respectfully requested that sentencing be continued until anytime after June 28, 2006. 6. After speaking with the Court's chambers, defense counsel was informed that the

Court is available to hold the sentencing hearing on June 29, 2006 at 9:30 a.m. 7. June 20, 2006. WHEREFORE, Mr. Bentley respectfully requests that the Court continue the sentencing hearing in this matter to June 29, 2006 at 9:30 a.m. Respectfully Submitted, Any objections to the presentence report will be filed by the defendant no later than

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Jeffrey Bentley

DATED:

May 18, 2006

2

Case 1:05-cr-00039-GMS

Document 25

Filed 05/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. JEFFREY BENTLEY, Defendant. : : : : : : : : :

Criminal Action No. 05-39-GMS

CERTIFICATE OF SERVICE The undersigned attorney for defendant Jeffrey Bentley hereby certifies that a copy of Defendant's Motion for Continuance of Sentencing is available for public viewing and downloading and was electronically delivered on May 18, 2006, to: Edmund Falgowski, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

The undersigned attorney further certifies that on May 18, 2006, a copy of the attached Motion for Continuance of Sentencing was placed in a box in the United States District Court of the District of Delaware addressed to the following person: Margaret Bray U. S. Probation Officer Suite 400, 824 Market Street Wilmington, DE 19801-3588

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Jeffrey Bentley