Free Order on Motion for Waiver of Speedy Trial Act - District Court of Delaware - Delaware

Case 1 :07-cr-00145-GIVIS Document 21 Filed 12/05/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
U Plaintiff,
v. Criminal Action No.07—l45—GMS
JOAN SANTIAGO,
Defendant.
MOTION AND ORDER TO EXCLUDE TIME
COMES NOW the United States of America, by and through Colm F. Connolly, United
States Attorney for the District of Delaware and Keith M. Rosen, Assistant United States
Attorney, and hereby moves this Honorable Court to exclude tmder the Speedy Trial Act, 18
U.S.C. § 3161, the time from the date of its Order granting this Motion until the rescheduled
motions deadline in this matter. In support thereof, the government states as follows: _
1. The defendant was arraigned in this matter on November 8, 2007. At that time,
Magistrate Judge Thynge entered an Order granting the defendant until November 27, 2007, to
file any pre—tria1 motions, and excluding the time from November 8, 2007, until November 27,
2007, under the Speedy Trial Act (“the Act").
2. On or about November 20, 2007, the defendant’s appointed counsel, Keir
Bradford, Esq., moved to withdraw her appearance. That motion was granted by the Court on
November 21, 2007, with the written Order filed on November 26, 2007. On December 3, 2007,
the government was notified by the Clerk’s Office that James Brose, Esq., had been appointed to
represent the defendant.

Case 1 :07-cr—00145-GIVIS Document 21 Filed 12/05/2007 Page 2 of 2
3. On or about the same date, the undersigned attorney for the govermnent spoke
with Mr. Brose. Mr. Brose requested a forty-tive (45) day extension (until January 17, 2008) to
tile motions. The length of this extension was requested in part due to the upcoming holidays.
4. The government does not oppose the requested continuance of the motions
deadline. Further, the government respectfully submits that additional time to permit the
defendant’s new counsel an adequate opportunity to review the discovery in this matter and file
any pre—trial motions is in the interest of justice. Accordingly, the government submits that this
delay should be excluded under the Speedy Trial Act, and asks this Court to enter an Order
excluding time under the Act from the date of said Order until the date of the rescheduled
motions deadline. See 18 U.S.C. § 3 l6l(h)(8)(A).
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY:
Keith M. Rosen
Assistant United States Attorney
Dated: December 3, 2007
s lvl
IT IS SO ORDERED this day of , 007.
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Q
Hon able egory M. Slee
Chief Judge
United States District Court
District of Delaware
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Case 1:07-cr-00145-GMS

Document 21

Filed 12/05/2007

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Case 1:07-cr-00145-GMS

Document 21

Filed 12/05/2007

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