Free Stipulation - District Court of Delaware - Delaware

Case 1 :07-or-00047-SLR Document 24 Filed OCS/29/2007 Page 1 of 3
· I IN THE UNITED STATES DISTRICT COURT I
I FOR THE DISTRICT OF DELAWARE I l _ n he-
E UNITED STATES OF AIVIERICA, ) . _ · ·
.- Plaintiff, l - g ` l
A v. . g Criminal Action No. 07—47— SLR C
WTLFREDOA M. PINKSTON, g
Defendant. " i C
JOINT STIPULATION TO WITHDRAW MOTION TO-SUPPRESS _ I
NOW COMES, the United States of America, by and through the undersigned attorneys, Colm l C
F. Connolly, United States Attorney for the District of Delaware, and Martin C. Meltzer, Special
I Assistant United States Attorney for the District of Delaware, and oe Hurley Esquire, attorney for the
defendant, hereby respectfully submits a Joint Stipulation to withdraw the defendant’s Motion to
n _ » . Suppress and the government’s opposition in the above case. . I I - T
l - The above respectfully submits the following in support of their joint stipulation:
l. On July 23, 2007, the defendant filed a Motion to Suppress statements made by the defendant
p C after being taken into custody and prior to being given Miranda warnings. . E
l 2. The government has agreed it will not use the statements made by the defendant prior to him l
being given:Miranda in the government’s case-in-chief. . -
3. The statements provided by the defendant prior to being given Miranda are as follows: when
the defendant was asked why he ran to the rear of the building, he stated "he ran after his pit bull that A
chased a cat" to the rear of the vacant building. He also stated "he was on probation and did not have ·
anything? - n - I - ‘ _

_ Case 1 :07-or-00047-SLR Document 24 Filed 08/29/2007 Page 2 of 3
_ 5. The govemment and the defendant’s counsel jointly submit this stipulation and the
defe11dant’s counsel has authorized the government to sign this stipulation for him.
. _ _ · Respectfully submitted,
' _ COLM F. CONNOLLY
n United States Attorney
` /s/ Joe. Hurley, Esguirel /s/Martin C. Meltzer U
Joe Hurley Martin C. Meltzer e
Attorney for Defendant p Special Assistant United States Attorney ` -
‘ I `Dated: August 28, 2007 _
5 U _ U

_ I Case t :07-or-00047-SLR Document 24 Filed 08/29/2007 Page 3 of 3- `
_ IN THE UNITED STATES DISTRICT COURT .
p FOR THE DISTRICT OF DELAWARE · - ‘ p
- UNITED STATES OF AMERICA, ) 1 - 4 -
) ‘ E
. Plaintiff; ) .
v. ‘ ) Criminal Action No. 07-47- SLR _ -
_ A I )
WILFREDO M. PINKSTON, ` ) -
) · I
_ Defendant. )
I _ _ CERTIFICATE OF SERVICE v
I, Martin C. Meltzer, Special Assistant United States Attorney for the District of Delaware,
hereby certify that on the 29rd day of August, 2007, I caused to be filed a Joint Stipulation to l
withdraw the defendant’s Motion to Suppress in the above case with the Clerk of the Court. Said A
documents were served via the ECF system on counsel for the defendant: _ _ . `
J oe Hurley, Esquire A
1215 King Street ‘ _
_ t Wilmington, DE 19801 ‘ A n `
. ‘ ` l I /s/ Martin C. Meltzer .
p - Martin C. Meltzer A n . _
- . ‘ Special Assistant United States Attomey _ p