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

Case 1:07-cr-00156-GMS

Document 13

Filed 01/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ROBERT BUCKLEY, Defendant.

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Criminal Action No. 07-156-GMS :

MOTION TO EXTEND TIME TO FILE PRE-TRIAL MOTIONS Defendant, Robert Buckley, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court pursuant to Federal Rule of Criminal Procedure 45(b) and Local Rule 5(a), for an Order enlarging the time within which pre-trial motions may be filed. In support of this motion, the Defendant submits as follows: 1. 2. Pre-trial motions for this case are due by January 25, 2008. Defense counsel needs additional time to review the discovery in this case and to

discuss this case with Mr. Buckley, to determine what, if any, pre-trial motions need to be filed. The government has indicated to defense counsel that the forensic examination of a computer, that the government alleges belongs to Mr. Buckley, has produced a considerable amount of discovery that the government has not yet had the opportunity to share with defense counsel. 3. Assistant United States Attorney, Edmond Falgowski, the attorney handling this case

for the government, does not oppose the defense's request for an enlargement of time in which to file any pre-trial motions, making this motion unopposed.

Case 1:07-cr-00156-GMS

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Filed 01/25/2008

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4.

Defense counsel, therefore, respectfully requests an additional 30 days in which to

file pre-trial motions, to allow her sufficient time to review the discovery in this case and to discuss the case in general with Mr. Buckley. 5. The defense agrees to waive, pursuant to the Speedy Trial Act, any additional time

given in which to file pre-trial motions. WHEREFORE, it is respectfully requested that the time for Defendant to file pre-trial motions be extended to anytime after February 25, 2008.

Respectfully Submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Robert Buckley

Dated: January 25, 2008

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Case 1:07-cr-00156-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ROBERT BUCKLEY, Defendant.

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Criminal Action No. 07-156-GMS

ORDER Having considered Defendant Buckley's Motion to Extend Time to File Pre-trial Motions, IT IS HEREBY ORDERED this motions in this matter shall be due on the day of day of , 2008, that pre-trial , 2008, and

that the time from January 25, 2008 up to the new due date for pre-trial motions to be filed 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