Free Motion to Continue - District Court of Delaware - Delaware

Case 1:08-cr-00060-GMS

Document 17

Filed 05/16/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. MALIK SAMUELS, Defendant. : : : : : : : : :

Criminal Action No. 08-60-GMS

MOTION FOR CONTINUANCE OF SCHEDULING CONFERENCE Defendant, Malik Samuels, through undersigned counsel, Eleni Kousoulis, hereby moves this Honorable Court for an Order continuing the scheduling conference in this case. In support of this motion, the defense submits as follows: 1. 9:30 a.m. 2. Defense counsel will be out of the office attending a conference from May 27, 2008 A scheduling conference in this matter is currently scheduled for May 29, 2008, at

through May 30, 2008, and not returning to the office until June 2, 2008. Therefore, defense counsel will be unavailable on May 29, 2008, the date that Mr. Samuels' scheduling conference is currently scheduled. 3. continued.1 4. Defense counsel was unable to reach Assistant United States Attorney, Robert Defense counsel respectfully requests that Mr. Samuels' scheduling conference be

Kravetz, the attorney handling this case for the government, to ascertain the government's position Defense counsel will be out of the office and unavailable on May 23, 2008, June 5, 2008 and June 6, 2008.
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Case 1:08-cr-00060-GMS

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on the defense's continuance request. 5. The Defendant agrees to waive the time from May 29, 2008, until the date of the

continuance for purposes of the Speedy Trial Act (18 U.S.C. § 3161, et seq.). WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the defendant respectfully requests a continuance of scheduling conference in this case.

Respectfully submitted, /s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, DE 19801 302-573-6010 [email protected] Attorney for Defendant Malik Samuels Dated: May 16, 2008

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Case 1:08-cr-00060-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. MALIK SAMUELS, Defendant. : : : : : : : : :

Criminal Action No. 08-60-GMS

ORDER The Court having considered the Defendant's Motion for Continuance of Scheduling Conference, good cause having been shown therefore; IT IS HEREBY ORDERED this day of , 2008 that the

Defendant's motion is hereby granted, and the scheduling conference in this case is rescheduled for the _______ day of _______________, 2008, and that the time from May 29, 2008 up to the day of the scheduling conference shall be excluded under the Speedy Trial Act (18 U.S.C. § 3161, et seq.).

Honorable Gregory M. Sleet Chief Judge, United States District Court