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

Case 1:07-cr-00149-SLR

Document 71

Filed 01/24/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) )

UNITED STATES OF AMERICA, Plaintiff, v. DARNELL MORRIS, Defendant.

Case No. 07-149-SLR

MOTION TO EXTEND TIME TO FILE PRETRIAL MOTIONS Defendant, Darnell Morris, by his attorney, Kathleen M. Jennings, Esquire, respectfully moves this Honorable Court to extend the deadline for filing pretrial motions for the following reasons: 1. Defendant has been charged with conspiracy to distribute more than 500 grams of

cocaine and possession with intent to distribute greater than 500 grams of cocaine. 2. 3. Pretrial motions were scheduled to be filed on January 22, 2008. Defense counsel has received substantial discovery but is awaiting additional

materials, including recorded statements, evidence log and Medical Examiner's Report. 4. 5. Assistant United States Attorney Keith Rosen does not object to this request. The Government will not be prejudiced by the instant request because it is the

first request for an extension of time to file pretrial motions and will not affect scheduling of court dates. 6. Counsel for Defendant has been out of the country since January 10, 2008 and

only returned to work on January 23, 2008. 7. Counsel for Nathan Weeks obtained an extension until March 25, 2008.

Case 1:07-cr-00149-SLR

Document 71

Filed 01/24/2008

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WHEREFORE, Defendant respectfully requests this Court to extend the time to file pretrial motions to March 25, 2008. OBERLY, JENNINGS & RHODUNDA, P.A.

/s/ Kathleen M. Jennings Kathleen M. Jennings, Esquire (No. 913) 1220 N. Market Street, Suite 710 P.O. Box 2054 Wilmington, DE 19899 (302) 576-2000 ­ Telephone (302) 576-2004 ­ Facsimile Counsel for Defendant

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Case 1:07-cr-00149-SLR

Document 71-2

Filed 01/24/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) )

UNITED STATES OF AMERICA, Plaintiff, v. DARNELL MORRIS, Defendant.

Case No. 07-149-SLR

ORDER On this _____ day of ________________, 2008, is it hereby ORDERED and DECREED that Defendant's Motion to Extend Time to File Pretrial Motions is granted, and all pretrial motions shall be filed on or before March 25, 2008.

The Honorable Sue L. Robinson