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

Case 1:08-cr-00094-SLR

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Filed 07/14/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ____________________________________________________________ : : VS. : CRIMINAL NO. 08-94-SLR : JOSHUA BEY : __________________________________________________________ DEFENDANT JOSHUA BEY'S MOTION FOR ADDITIONAL TIME TO FILE PRE-TRIAL MOTIONS Joshua Bey, by and through his attorney, James F. UNITED STATES OF AMERICA

Brose, moves the court pursuant to Federal Rule of Criminal Procedure Number 12 for additional time to file pre-trial motions, and in support thereof states the following: 1. On July 3, 2008, defendant Joshua Bey (hereinafter

"Bey") was arraigned on a charge of Unlawful Possession of a Firearm in violation of 18 U.S.C. §922(g)(1) and 18 U.S.C. §924(a)(2). 2. By order of Magistrate Judge Stark, Bey was given

until July 17, 2008 to file pretrial motions. 3. Defendant received the first batch of discovery in

this case from the government on July 8, 2008. 4. Defendant needs additional time to review the

discovery in this matter and to investigate certain matters related to the case, specifically, the facts underlying the issuance of the search warrant in the case. 5. On July 14, 2008, Assistant United States Attorney

Geoff Grivener informed defense counsel he has no objection

Case 1:08-cr-00094-SLR

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Filed 07/14/2008

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to

Bey's

request

for

additional

time

to

file

pre-trial

motions. WHEREFORE, under 18 U.S.C. §3161 and Federal Rule of Criminal Procedure 12, the defendant respectfully requests that the Court grant this motion and enter the attached order granting additional time to file pre-trial motions. Respectfully Submitted,

/s/ Jame F. Brose James F. Brose 206 South Avenue Media, PA 19063 610-891-1989

Case 1:08-cr-00094-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ____________________________________________________________ UNITED STATES OF AMERICA : : VS. : CRIMINAL NO. 08-94-SLR : JOSHUA BEY : __________________________________________________________ ORDER AND NOW, this day of , 2008, upon

consideration of Defendant's Motion for Additional Time to File Pre-trial motions, the Court finds that additional time is needed because: 1. Defense counsel requires additional time to review and

investigat the discovery materials. THEREFORE, IT IS ORDERED, in accordance with Federal Rule of Criminal Procedure Number 12, that the defendant shall have

thirty (30) days to file pre-trial motions after receipt of discovery provided by the government. BY THE COURT: , J.

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CERTIFICATION OF SERVICE I, James F. Brose, hereby certify that I caused to be electronically filed a copy of the foregoing documents with the Clerk of Courts using CMECF, which will send

notification that such filing is available for viewing and downloading to the following counsel of record: Geoff Grivener, Esq. United States Attorney's Office 1007 Orange Street, Suite 700 P.O. Box 2046 Wilmington, DE 19899-2046

Date: July 14, 2008

/s/ James F. Brose