Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00078-JJF

Document 9

Filed 09/14/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. WADE GRAY, Defendant.

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Criminal Action No. 07-78-JJF

MOTION FOR CHANGE IN TIME OF CHANGE OF PLEA HEARING The defendant, Wade Gray, through undersigned counsel Eleni Kousoulis, hereby moves this Honorable Court for an Order changing the time of the Change of Plea Hearing in this case. In support of this motion, the defense submits as follows: 1. A Change of Plea Hearing in this matter is currently scheduled for September 21, 2007 at 9:00 a.m. 2. Defense counsel has a Change of Plea and Sentencing on another matter scheduled

for 8:30 a.m. on September 21, 2007, and does not anticipate that hearing being completed by 9:00 a.m. Defense counsel respectfully requests that the time of Mr. Gray's Change of Plea Hearing be changed. 3. AUSA Leslie Wolf, the attorney handling this case for the government, has

no objection to the defense's change in time request. 4. All parties are available anytime between 9:30 a.m. until 12:00 noon on September

Case 1:07-cr-00078-JJF

Document 9

Filed 09/14/2007

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21, 2007. Defense counsel has another hearing scheduled at 12:00 noon on September 21st, and AUSA Leslie Wolf is only available until 12:00 noon on this date.1 WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the defense respectfully requests a change in time of the Change of Plea Hearing in this case. Respectfully submitted, /s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, DE 19801 Counsel for Defendant Wade Gray

Dated: September 14, 2007

Should the Court be unable to hold Mr. Gray's Change of Plea hearing between 9:30 a.m. to 12:00 noon on September 21, 2007, defense counsel respectfully requests that the Change of Plea Hearing be re-scheduled for another date, and agrees to waive the time pursuant to the Speedy Trial Act. 2

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Case 1:07-cr-00078-JJF

Document 9-2

Filed 09/14/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. WADE GRAY, Defendant.

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Criminal Action No. 07-78-JJF

ORDER The Court having considered Defendant Gray's Motion for Change in Time of Change of Plea Hearing, and good cause having been shown therefore; IT IS HEREBY ORDERED this day of , 2007,

that Wade Gray's Change of Plea Hearing shall be re-scheduled for the ________ day of _____________________ , 2007 at __________ a.m./p.m.

Honorable Joseph J. Farnan, Jr. United States District Court