Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1:08-cr-00112-JJF Document 11 Filed 08/28/2008 Page 1 of 4
UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Cr. A. N0. 08-112-JJF
)
JOSHUA TARBURTON, ) .
J
Defendant. )
NOTICE OF MOTION
To: John C. Snyder, Esquire
Assistant United States Attorney
Nemours Building
1007 N. Orange Street, Suite 700
P.O. Box 2046
Wilmington, DE 19899-2046
PLEASE TAKE NOTICE that the within Motion for Extension of Time within which to
tile Motions will be presented to The Honorable Joseph J. Farnan, Jr. as soon as counsel can be
heard.
/s/ Eugene J. Maurer, Jr.
Eugene J. Maurer, Jr., I.D. #821
1201-A King Street
Wilmington, DE 19801
302-652-7900
Attorney for Defendant p
Date: August 28, 2008 2

Case 1 :08-cr-00112-JJF Document 11 Filed 08/28/2008 Page 2 of 4
UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, i
v. g Cr. A. No. 08-I l2—JJF
JOSHUA TARBURTON, g
Defendant. i
MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE MOTIONS
COMES NOW the defendant, through his attorney Eugene J. Maurer, Jr., and
respectfully requests that the time within which motions are to be filed in this case be extended
to September 8, 2008. The bases of this motion are as follows: A
l. Counsel represents the defendant in a three count indictment alleging firearms and
explosive devices.
2. At arraignment in the above, the court set a motions deadline for August 28, 2008.
3. Counsel received the govern.ment’s discovery package on or about August 15, 2008.
4. In reviewing the discovery materials, it appears that there may be a significant search and
seizure issue as it relates to the search of the defendant’s residence.
5. Inasmuch as the issue involves factual questions regarding what occurred, counsel needs
time to confer with his client and his client’s mother who is a witness to the events in
question. The defendant is incarcerated in Salem County and the mother resides in
Sussex County. C

Case 1 :08-cr-00112-JJF Document 11 Filed 08/28/2008 Page 3 of 4
6. ln order to gather the appropriate facts to make a determination as to whether or not a
suppression motion would be well-founded in this case, counsel respectfully requests that
the motion deadline previously set he extended to September 8, 2008.
/s/ Eugene J. Maurer, Jr.
Eugene J. Maurer, Jr., l.D. 821
1201-A King Street
Wilmington, DE 19801
302-652-7900
Attorney for Defendant
Date: August 28, 2008

Case 1 :08-cr-00112-JJF Document 11 Filed 08/28/2008 Page 4 of 4
UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
Plaintiff, i
v. i Cr. A. No. 08-I I2-IIE
JOSHUA TARBURTON, i
Defendant. i
QBE
AND NOW, to wit, this day of , 2008, the foregoing
motion have been heard and considered, it is hereby
ORDERED that the time within which to file motions inthe above is extended to
September 8, 2008.
I

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