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

I Case 1 :07-cr-00146-GIVIS Document 16 Filed 12/03/2007 Page 1 013 g I I l
- I IN THE UNITED STATES DISTRICT COURT
T FOR THE DISTRICT OF DELAWARE
_ UNITED STATES OF AMERICA, i :
U _ Plaintiff, U
v. Criminal Action No.07-146-GMS
HUGO OLGUIN-LOPEZ, zi I
_ cz/No Hugo Lopez-Olguirz, :
· a/Ha Anthony R. Sanchez, : _
_ I Defendant.
I MOTION AND ORDER To EXCLUDE TIME
I ‘ I COMES NOW the United States of America, by and through Colm F. Connolly, United
_ ` U 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
I I motions deadline in this matter. In support thereof the government states as follows: -
I I 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 fi
I I tile any pre-trial motions, and excluding the time from November 8, 2007, until November 27,
2007, under the Speedy Trial Act ("the Act"). `
I 2. The defendant did not file any motions prior to the November 27, 2007, deadline. I p
By letter dated November 29, 2007, Thomas Pedersen, Esq., entered his appearance on behalf of in
the defendant and requested an extension until December 27, 2007, to tile motions. The · -
. defendant had been represented by Ubel Velez, Esq. 7 I . I

A . Case 1 :07-cr-00146-GIVIS Document 16 Filed 12/O3/2007 Page 2 of 3
. A 3. The government does not oppose the requested continuance of the motions
y 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
I 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. § 3l6l(h)(8)(A). _
I · Respectfully submitted,
I COLM F. CONNOLLY
United States Attorney
I BY: /
. Keith M. Rosen
. . Assistant United States Attorney
Dated: December 3, 2007
IT IS SO ORDERED this day of , 2007.
Honorable Gregory M. Sleet U
` · Chief Judge
. ‘ l . United States District Court {
‘ " District of Delaware I I I

Case 1 :07-cr—OO146-GIVIS Document 16 Filed 12/O3/2007 Page 3 of.3
· CERTIFICATE OF SERVICE L
UNITED STATES OF AMERICA )
1
v. ) Criminal Action No. 07-146-GMS
) ~ .
HUGO OLGUIN-LOPEZ, ) _ .
a/k/a Jugo Lopez-Olguin, ) -
rz/k/a Anthony R. Sanchez ) _
I I, Sharon L. Bernardo, employee with the United States Attorney's Office, hereby certifythat _
on December 3, 2-007, I served the foregoing: l
MOTION AND ORDER TO EXCLUDE TIl\/IE -
by causing copies of said document to be placed in apostage prepaid envelope, placed in the United
States Mail, and addressed to counsel of record and also to be telefaxed as follows: - n
THOMAS A. PEDERSEN, ESQUIRE . .
2 N. Race Street ` _
Georgetown, DE 19947
Telefax: 302-856-7745

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