Free Letter - District Court of Delaware - Delaware

Case 1:05-cr-00020-SLR

Document 17-2

Filed 06/28/2005

Page 1 of 1

TALKIN, MUCCIGROSSO & ROBERTS, L.L.P.
40 EXCHANGE PLACE 18th FLOOR NEW YORK, NEW YORK 10005 PHONE:(212) 482-0007 FAX: (212) 482-1303 www.talkinlaw.com email:[email protected] Maryland Office: 5100 Dorsey Hall Drive Suite 100 Ellicott City, MD 21042 (410) 964-0300 New Jersey Office: 79 Main Street Suite One Hackensack, NJ 07601 (201) 342-6665

June 27, 2005 Honorable Kent A. Jordan United States District Judge District of Delaware 844 N. King Street, Room 6325 Wilmington, DE 19801 Re: United States v. Joseph DeStefano Cr. Action 05-20 (KAJ)

Dear Judge Jordan: By this letter, defendant respectfully requests a thirty day extension for the time to file motions. The parties are in plea negotiations which we expect to culminate with a plea well before the the thirty day period expires. This request is a precautionary measure to preserve the defendant's rights. I apologize for the lateness of this request. I am currently engaged in trial before the Honorable Leonard Sand in the United States District Court for the Southern District of New York. Additionally, the Pro Hac Vice and Substitution of Counsel paperwork was not completed and filed until June 23, 2005. This letter is being faxed to Chambers this evening and will be electronically filed by local counsel tomorrow. Thank you for Your Honor's consideration of this request.

Very truly yours, S/ Sanford N. Talkin cc: Kathleen Jennings, Esq. AUSA Anne Y. Park