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

Case 1 :08-cr-00001-GIVIS Document 15 Filed 06/O3/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiftj p
v. Criminal Action No. 08-01 GMS
ANTHONY J. LOFINK,
Defendant. _
p GOVERNMENT’S MOTION FOR ADDITIONAL TIME TO A
RESPOND TO DEFENDANT’S SENTENCING MEMORANDUM
COMES NOW the United States of America, by and through its attorneys, Colm F.
3 Connolly, United States Attorney for the District of Delaware, and David C. Weiss, First _
Assistant United States Attorney, and hereby moves for additional time to respond to A
Defendant’s Sentencing Memorandum for the reasons set forth below:
1. Sentencing in the above case is scheduled for June 26, 2008, at 9:30 a.m.
2. Defendant’s Sentencing Memorandum is due on June ll, 2008. Defendant’s
Sentencing Memorandum is expected to include a request for a departure based on diminished g
capacity under Section 5K2.l3 of the Sentencing Guidelines, and will be predicated on the
opinions of two experts. Presumably, the Defendant will also argue the application of the
sentencing factors set forth in 18 U.S.C. §3553(a). _
· 3. The Government’s Response to Defendant’s Sentencing Memorandum is due on or
before June 18, 2008. Counsel for the Government is on vacation from June ll through June 17,
2008.

Case 1:08-cr-00001-GIVIS Document 15 Filed 06/O3/2008 Page 2 of 3
4. The Government respectfully requests an additional two days, until Friday, June 20,
2008, to review Defendant’s Sentencing Memorandum and prepare its Response. l
5. Counsel for Defendant has indicated that he has no objection to this request.
VVHEREFORE, for the reasons set forth above, the United States respectfully requests an
additional two days to tile the Government’s Response to Defendant’s Sentencing Memorandum.
. COLM F. CONNOLLY
United States Attorney
BY?
David C. Weiss ~
U First Assistant United States Attorney
DATED: June 3, 2008

Case 1:08-cr-00001-GIVIS Document 15 Filed 06/O3/2008 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
V. Criminal Action No. 08-01 GMS
ANTHONY I. LOFINK, I
Defendant.
ORDER
AND NOW, this day of , 2008, upon consideration
of the Govemmenfs Motion for Additional Time to Respond to Defendant’s Sentencing
Memorandum, l
IT IS HEREBY ORDERED that the Motion is GRANTED. I
_ Honorable Gregory M. Sleet 8
Chief Judge

Case 1:08-cr-00001-GMS

Document 15

Filed 06/03/2008

Page 1 of 3

Case 1:08-cr-00001-GMS

Document 15

Filed 06/03/2008

Page 2 of 3

Case 1:08-cr-00001-GMS

Document 15

Filed 06/03/2008

Page 3 of 3