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

Case 1:07-cr-00145-GIVIS Document 20 p Filed 12/Od/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
n Plaintiff, . ‘
v. Criminal Action No.07-145-GMS
JOAN SANTIAGO, I
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 under 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, e
Magistrate Judge Thynge entered an Order granting the defendant until November 27, 2007, to
file any pre—trial motions, and excluding the time from November 8, 2007, tmtil November 27,
2007, under the Speedy Trial Act ("the Act").
2. On or about November 20, 2007, the dcfendant’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, E
the govemrnent 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 20 Filed 12/O4/2007 Page 2 of 3
3. On or about the same date, the undersigned attorney for the government 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 ofthe 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 tile
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 ofthe rescheduled
motions deadline. See 18 U.S.C. § 3 l61(h)(8)(A).
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY;
Keith M. Rosen
Assistant United States Attorney
Dated: December 3, 2007
IT IS SO ORDERED this day of , 2007.
Honorable Gregory M. Sleet
Chief Judge
United States District Court (
District of Delaware
`

Case 1 :07-cr-00145-GIVIS Document 20 Filed 12/04/2007 Page 3 of 3
CERTIFICATE OF SERVICE ·
UNITED STATES OF AMERICA )
) .
v. ) Criminal Action No. 07-145-GMS
0 )
JOAN SANTIAGO )
I, Sharon L. Bernardo, employee with the United States Attorney's Office, hereby certify that
on December 4, 2007, I served the foregoing: ‘ n
I MOTION AND ORDER TO EXCLUDE TIME
by causing two copies of said document to be hand delivered to counsel of record as follows:
James Brose, Esquire
206 South Avenue
Media, PA 19063

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