Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00087-SLR

Document 12

Filed 07/30/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ALFREDITO CAMPUSANO, Defendant.

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Criminal Action No. 07-87-SLR

MOTION FOR CONTINUANCE OF CHANGE OF PLEA AND SENTENCING Defendant, Alfredito Campusano, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court for an Order continuing the Change of Plea and Sentencing Hearing in this case. In support of the motion, the defense submits as follows: 1. Mr. Campusano is scheduled for a Change of Plea and Sentencing Hearing on

September 12, 2007, at 8:30 a.m. 2. Defense counsel, Eleni Kousoulis, will be out of the office and unavailable on

September 12, 2007, at 8:30 a.m. Ms. Kousoulis respectfully requests a continuance of the Change of Plea and Sentencing Hearing in this case. 3. AUSA Beth Moskow-Schnoll, the attorney handling this case for the government, has

no objection to the defense's request for a continuance in this matter. 4. Defense counsel spoke to the Court's chambers and was informed that the Court has

available September 21, 2007, at 8:30 a.m., in which to hold the Change of Plea and Sentencing Hearing in this matter.

Case 1:07-cr-00087-SLR

Document 12

Filed 07/30/2007

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5.

The defense agrees to waive any time, pursuant to the Speedy Trial Act, between now

and the new date of the hearing. WHEREFORE, Mr. Campusano respectfully requests that the Court continue the Change of Plea and Sentencing Hearing in this matter to September 21, 2007, at 8:30 a.m. Respectfully Submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Alfredito Campusano

DATED: July 30, 2007

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Case 1:07-cr-00087-SLR

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Filed 07/30/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ALFREDITO CAMPUSANO, Defendant.

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Criminal Action No. 07-87-SLR

ORDER In response to Mr. Campusano's Motion for Continuance of Change of Plea and Sentencing, this Court HEREBY ORDERS on this ________day of __________________, 2007, that Defendant's Sentencing Hearing is re-scheduled for the _______ day of _______________, 2007 at _________ a.m./p.m.

The Honorable Sue L. Robinson United States District Court