Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00140-GIVIS Document 9 Filed 11/29/2007 Page 1 of 3
I IN THE UNITED STATES DISTRICT COURT
- FOR THE DISTRICT OF DELAWARE
I UNITED STATES OF AMERICA, )
I ‘ I Plaintiff} I 3 _
. v. g Criminal Action No. 07-140-GMS I
I MANUEL MEDLEY, i
’ . Defendant. g U
- I JOINT MOTION TO CONTINUE ARRAIGNMENT AND FOR EXCLUSION OF TIME I
NOW COMES the United States of America, by and through its attorneys, Colm F. Connolly,
I I United States Attorney for the District of Delaware, and Shawn A. Weede, Assistant United States .
_ Attorney for the District of Delaware, and the defendant, Manuel Medley, by and through his p
attorney, Joseph W. Benson, Esquire, and hereby submit the following:
- I l. On October 23, 2007, the defendant was indicted with two counts of being a felon I I I
in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(l) and 924(a)(2), and one count of I
possession with intent to deliver_50 grams or more of cocaine base, in violation of 21 U.S.C. §§
I 8I4l(a)(l) (b)(l)(A). ` `
. 2. On October 25, 2007, the defendant stipulated to the Governrnent’s Motion for `
. _I Detention. On the same date, the defendant further agreed to continue his arraignment until
‘ November 25, 2007. I .
I 3. The parties are currently involved in plea negotiations and the Govermnent has I
‘ not yet completed discovery. Accordingly, the parties believe that additional time may benefit the I
I resolution of this case.
‘ 4. The parties resp eIctfully request that the Court continue the defendant’s arraignment I
until the week of December 31, 2007. The parties further request that the Court exclude the time 5

f I · I Case 1:07-cr-00140-GIVIS Document 9 Filed 11/29/2007 Page 2 of 3
from the date of this motion until the date ofthe arraignment, under the Speedy Trial Act (18 U.S.C.
" § 3161 et seq.), The parties submit that the time is excludable because the ends of justice served by
I the delay outweigh the best interest of the public and the defendant in a speedy trial. See 18 U.S.C.
§ 3 161(h). .
WHEREFORE, the parties respectfullyrequest that the Court grant their Joint Motion
_ to Continue Arraignment and for Exclusion of Time. A proposed Order is attached.
- I I I · I Respectfully submitted, I I
COLM F. CONNOLLY
United States Attorney
By: /s/ J osgph W. Benson . By: /s/ Shawn A. Weede
Joseph W. Benson Shawn A. Weede
Attorney for Manuel Medley Assistant United States Attorney
Dated: November 29, 2007 I I .

Case 1 :07-cr-00140LGIV|S · Document 9 Filed 11/29/2007 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE · .
‘ I UNITED STATES OF AMERICA, ) I
I Plaintifii g
Q v. g Criminal Action No. 07-l40·GMS
MANUEL MEDLEY, I l
I Defendant. I g I
I Having considered the parties’ Joint Motion to Continue Arraignment and for Exclusion of I
- Time, IT IS HEREBY ORDERED that the arraignment in this matter is continued and scheduled
for the week of December 31, 2007.
_- IT IS FURTHER ORDERED that the period from November 29, 2007, through the date I
ofthe arraig1nnentis`excluded under the Speedy Trial Act, because the ends of justice served by the I I
delay outweigh the best interest ofthe public and the defendant in a speedy trial. See 18 U.S.C. § I
3161(h). II . -
. p _ . I United States Magistrate Judge · . I
Dated: _ _ _ · ‘ III Ip

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