Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

· Case 1 :08-cr-OOOEO—SLR Document 8 Filed O4/O4/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA ) n
` Plaintiff, g
v. g Criminal Action No. 08-20-SLR
JOHNTEL CLARK, I I g I
Defendant. l
MOTION FOR SCHEDULING OR STATUS CONFERENCE
NOW COMES the United States of America, by and through its attorney, Colm F. Connolly,
_ United States Attorney for the District of Delaware, and hereby moves for a scheduling or status l
teleconference in the above-captioned case. The parties are currently engaged in plea negotiations
a.nd expect that the defendant will plead guilty to the charges in the indictment as well as charges
relating to crimes committed in three other federal districts ("the non-Delaware charges"). The
government is in the process of completing its production of discovery for the non-D elaware charges.
The government is also currently engaged in discussions with the prosecutorial authorities in the
other districts to obtain the consent of those authorities to dispose of all charges in this proceeding.
The govemment respectfully requests a teleconference with the Court to set a date for a Rule ll
hearing and inform the Court as to the status of the parties’ efforts to resolve this ca-se.
The United States further requests that the Court exclude under the Speedy Trial Act any time
from the date of the filing of this Motion, until the date of the scheduling or status teleconference. A

Case 1:08-cr-00020-SLR Document 8 Filed O4/O4/2008 Page 2 of 2
The United States submits that the ends of j ustice served by the continuance would outweigh the
interests ofthe public and the defendant in a speedy trial. See 18 U.S.C. § 3l6l(h)(8)(A).
Respectfully submitted,
Colm F. Connolly g
- United States Attorney
Dated: April 4, 2008 p

Case 1:08-cr-00020-SLR

Document 8

Filed 04/04/2008

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Case 1:08-cr-00020-SLR

Document 8

Filed 04/04/2008

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