Free Motion to Continue - District Court of Delaware - Delaware

Case 1:98-cr-00038-SLR

Document 62

Filed 08/11/2006

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA Plaintiff, v. SHAWN CUFF, Defendant.

: : : : : : : : :

Criminal Action No. 98-038-SLR

MOTION FOR CONTINUANCE OF VIOLATION HEARING Defendant, Shawn Cuff, by and through his undersigned counsel, Christopher S. Koyste, hereby moves the Court for an order continuing the August 23, 2006 violation of supervised release hearing to September 6, 2006 at 4:45 p.m. Counsel submits the following in support thereof: 1. On July 13, 2006 a petition to violate Mr. Cuff's term of supervised release was filed by USPO Craig Carpenter. A summons was issued and Mr. Cuff appeared for his initial appearance on August 10, 2006. A violation hearing was scheduled for August 23, 2006. Council has been scheduled to take annual leave on this day and respectfully requests a continuance of the hearing. 2. USPO Craig Carpenter does not oppose this request for rescheduling of the sentencing

hearing. Council attempted but could not reach AUSA Richard G. Andrews, who is on annual leave this week, as well as the duty attorney for the United States Attorney's Office.

Case 1:98-cr-00038-SLR

Document 62

Filed 08/11/2006

Page 2 of 3

WHEREFORE, Mr. Cuff respectfully requests the Court to continue the sentencing hearing to September 6, 2006 at 4:45 p.m.

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

DATED: August 11, 2006

Case 1:98-cr-00038-SLR

Document 62

Filed 08/11/2006

Page 3 of 3

CERTIFICATE OF SERVICE Undersigned counsel certifies that his Motion for Continuance is available for public viewing and downloading and was electronically delivered on August 11, 2006 to:

Richard G. Andrews, 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 Shawn Cuff