Free Motion for Hearing - District Court of Delaware - Delaware

_ I Case 1 :08-cr-00106-GIVIS Document 9 Filed 07/23/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
)
v. ) Case N0. 08-
)
NELSON AVILES, )
)
Defendant. )
)
MOTION FOR HEARING
TO CONSIDER WAIVER OF INDICTMENT
AND GUILTY PLEA
Now comes the United States of America, by and through its counsel, Colm F. Connolly,
United States Attorney and Geoffrey G. Grivner, Special Assistant United States Attomey, and
the defendant, Nelson Aviles, by and through his counsel, Luis A. Ortiz, Esq. and hereby
respectfully request that the Court schedule and conduct a hearing to consider and accept the
defendant’s waiver of indictment and guilty plea. In support, the parties allege:
1. The defendant and his counsel have signed a waiver of indictment in the above case and the
defendant desires to enter a guilty plea pursuant to an already executed plea agreement once the
matter is scheduled before a District Court Judge. See Exhibit 1 (copy of waiver of indictment).
At the time of the filing of this motion, a copy of this executed plea agreement will be submitted

Case 1:08-cr-00106-GIVIS Document 9 Filed 07/23/2008 Page 2 of 3
to the Clerk"s Office for consideration by the District Court Judge when that Judge is assigned to
the case.
Wherefore, for the above—stated reason, the parties respectfully request that the Court
schedule and hold a hearing at the Court’s earliest convenience to consider and accept the
delcndant’s: l) waiver ofindictment and 2) guilty plea.
Respectfully submitted,
COLM F. CONNOLLY
UNITED STATES ATTORNEY
n
by
Geo y . Grivner uis A. Ortiz, Esq.
Special Assistant U.S. Attorney Attorney for Defendant
Date: Z·Z [JQ Date: 7 ‘8"O 2/

Case 1:08-or-00106-GIVIS Document 9 Filed 07/23/2008 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
)
V. > case NO. 08- [OQ
)
NELSON AVILES, )
)
Defendant. )
)
ORDER
Based upon the allegations in the Joint Motion For Hearing To Consider Waiver of
Indictment and Guilty Plea, the Court hereby schedules a hearing for the Defendant to proffer his
waiver of indictment and guilty plea at (a.m.)(p.m.) on , 2008 in
Courtroom _.
United States District Court Judge
Date: July _, 2008

Case 1:08-cr-00106-GMS

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