Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00153-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLENE HUSS, Defendant.

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Criminal Action No. 07-153-JJF

MOTION FOR CONTINUANCE OF SCHEDULING CONFERENCE The Defendant, Charlene Huss, by and through her counsel, Luis A. Ortiz, Esquire, hereby moves the Court for an order continuing the scheduling conference in this case. In support of the motion, the defense submits as follows: 1. at 11:00 a.m. 2. The Defendant, Charlene Huss, intends to eliminate a substantial portion of her A scheduling conference in this matter is scheduled for Wednesday, August 13, 2008,

restitution in this case by paying of a title loan on a vehicle that was allegedly obtained illegally in this case. Her family is refinancing the family home and has agreed to pay the title loan. Settlement on the refinancing is tentatively scheduled for August 30, 2008. 3. The government and defense counsel are currently discussing a non-trial disposition

of this matter. The parties agree that the payment of the title loan may have a significant positive effect on the ongoing negotiations regarding Mrs. Huss. 4. Accordingly, the defense respectfully requests that the scheduling conference be

continued 45 days in order to complete all negotiations

Case 1:07-cr-00153-JJF

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5.

Assistant United States Attorney, Lesley F. Wolf, counsel for the government, does

not oppose the defense's request for a continuance of the scheduling conference. 6. The defense agrees to waive, pursuant to the Speedy Trial Act, any time between

August 30, 2008, and the date of the scheduling conference. 7. Mrs. Huss has no objection to this request for a continuance.

WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the defense respectfully requests that the scheduling conference in this case be re-scheduled to another date.

Respectfully Submitted,

/s/ Luis A. Ortiz Luis A. Ortiz, Esquire Assistant Federal Public Defender One Customs House 704 King Street, Suite 110 Wilmington, Delaware 19801 302-573-6010 [email protected] Counsel for Defendant Charlene Huss Dated: July 28, 2008

Case 1:07-cr-00153-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLENE HUSS, Defendant.

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Criminal Action No. 07-153-JJF

ORDER In response to Defense's Motion for Continuance of Scheduling Conference, this Court HEREBY ORDERS on this _______day of ________________, 2008, that Mrs. Huss' scheduling conference be re-scheduled for the ________ day of ______________________, 2008 at _________ a.m./p.m., and that the time from August 13, 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 JOSEPH J. FARNAN, JR. United States District Court