Free Motion to Continue - District Court of Delaware - Delaware

Case 1:08-cr-00005-SLR

Document 20

Filed 04/30/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. TERRENCE ROSS, Defendant.

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Criminal Action No. 08-05-SLR

MOTION FOR CONTINUANCE OF EVIDENTIARY HEARING The Defendant, Terrence Ross, by and through his counsel, Eleni Kousoulis, Esquire, hereby moves the Court for an Order continuing the evidentiary hearing in this case. In support of the motion, the defense submits as follows: 1. 2. An evidentiary hearing in this matter is scheduled for April 30, 2008 at 4:00 p.m. The government has extended a plea offer to the Defendant in this case that was

initially presented to the Defendant on April 28, 2008, and the Defendant needs additional time to consider this offer. Should the Defendant accept this offer, an evidentiary hearing will not be needed. 3. The Defendant respectfully requests that the evidentiary hearing in this matter be

continued for at least two weeks to allow him adequate time to consider the government's offer. 4. Assistant United States Attorney, Ilana Eisenstein, does not oppose the Defendant's

request for a continuance. 5. The Defendant agrees to waive, pursuant to the Speedy Trial Act, any time between

April 30, 2008 and the rescheduled date for the hearing.

Case 1:08-cr-00005-SLR

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Filed 04/30/2008

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WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the Defendant, Terrence Ross, respectfully requests that the evidentiary hearing in this case be continued to any time after May 16, 2008.

Respectfully Submitted,

/s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 302-573-6010 [email protected] Counsel for Defendant Terrence Ross

Dated: April 30, 2008

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Case 1:08-cr-00005-SLR

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Filed 04/30/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. TERRENCE ROSS, Defendant.

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Criminal Action No. 08-05-SLR

ORDER In response to Defendant's Motion for Continuance of Evidentiary Hearing, this Court HEREBY ORDERS on this _________day of __________________, 2008, that Mr. Ross' evidentiary hearing be re-scheduled for the _________ day of _____________________, 2008, at _________ a.m./p.m., and that the time from April 30, 2008 up to the day of the re-scheduled evidentiary hearing shall be excluded under the Speedy Trial Act (18 U.S.C. § 3161, et seq.).

HONORABLE SUE L. ROBINSON United States District Court