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

Case 1:07-cr-00037-GMS

Document 14

Filed 06/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTOINE L. PATRICK, Defendant.

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Criminal Action No. 07-37-GMS

MOTION TO EXTEND TIME TO FILE PRE-TRIAL MOTIONS Defendant Antoine L. Patrick, by and through his undersigned counsel, Edson A. Bostic, hereby moves the Court, pursuant to Federal Rule of Criminal Procedure 45(b) and Local Rule 5(a), for an Order enlarging the time within which pre-trial motions may be filed. In support of this motion, Mr. Patrick submits as follows: 1. On or about March 22, 2007, Mr. Patrick was arraigned on the charges of being a

felon in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2), and for possession with the intent to distribute more than five grams of cocaine, in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(B)(iii). The matter was assigned to Christopher S. Koyste, Assistant Federal Public Defender, as trial counsel. 2. 3. An Order was entered directing that pre-trial motions be filed by June 8, 2007. On June 1, 2007, Mr. Koyste resigned from the Federal Public Defender's Office. As

such, Edson A. Bostic, Federal Public Defender, assumed the case as trial counsel. Because of the reassignment, Mr. Bostic needs additional time to meet with Mr. Patrick and familiarize himself with the case to determine what, if any, pretrial motions need to be filed.

Case 1:07-cr-00037-GMS

Document 14

Filed 06/07/2007

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4.

Seth Beausang, Assistant United States Attorney, counsel for the government, does

not oppose this request. 5. The parties have agreed that any additional time given in which to file pre-trial

motions will be excludable under the Speedy Trial Act. 6. Accordingly, Mr. Patrick respectfully requests a two week extension of time in which

to file any pre-trial motions. WHEREFORE, it is respectfully requested that the time for Mr. Patrick to file pre-trial motions be extended until June 22, 2007.

Respectfully Submitted,

/s/ Edson A. Bostic Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Antoine L. Patrick

Dated: June 7, 2007

Case 1:07-cr-00037-GMS

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Filed 06/07/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTOINE L. PATRICK, Defendant.

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Criminal Action No. 07-37-GMS

ORDER Having considered Defendant's Motion to Extend Time to File Pretrial Motions, IT IS HEREBY ORDERED this day of day of , 2007, that Defendant , 2007.

Antoine L. Patrick's pretrial motions shall be due on the

Honorable Gregory M. Sleet United States District Court