Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1 :07-cr-00025-JJF Document 34 Filed O9/24/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Criminal Action N0. 07-25-JJF
)
)
)
ROBERT COTTMAN, III, )
)
Defendant. )
)
MOTION TO AUTHORIZE THE UNITED STATES
AND DEFENSE COUNSEL ACCESS TO FEDERAL DETAINEE
FOR A VIDEOTAPED INTERVIEW FOR EDUCATIONAL, PROMOTIONAL
AND DETERRENCE PURPOSES
A The United States, by and through its attorneys Colm F. Connolly, United States
Attorney for the District of Delaware and Robert J. Prettyman, Assistant United States Attorney,
and the Defendant Robert Cottman, HI, by and through his attorney, Edson Bostic, Esq., hereby
respectfully request that this Honorable Court authorize the United States and defense counsel
access to federal detainee Defendant Robert Cottman, lll so that the Defendant may participate
in a videotaped statement/interview that the United States and its employees may use for
educational, promotional, deterrent and related purposes in support of law enforcement
initiatives, including Operation FED UP, Proj ect Safe Neighborhoods, and Operation Disarm. In
support, the parties allege:

Case 1 :07-cr-00025-JJF Document 34 Filed O9/24/2007 Page 2 of 3
1. On July 30, 2007, the Defendant entered a conditional plea of guilty to Counts One, Two
and Three of the Indictment in the above case. Counts One and Two of the Indictment charge
the defendant with being a felon in possession of a firearm, in violation of 18 U.S.C.
§§ 922(g)(1) and 924(a)(2). Count Three charges the defendant with being a felon in possession
of ammunition, also in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). The Defendant is
awaiting sentencing.
2. The Defendant is currently detained federally on the above charges at the Salem County
(New Jersey) Detention Center.
3. The United States and the Defendant have agreed that the Defendant will participate in a
videotaped statement/interview at the Salem County Detention Center that may be used by the
United States for educational, promotional and deterrent purposes in support of various law
enforcement outreach initiatives including Operation F ED UP, Proj ect Safe Neighborhoods, and
Operation Disarm programs, and the Defendant expressly consents to the above use.
4. The Defendant is seeking sentencing consideration based upon his participation in the
videotaped statement/interview referenced in paragraph three of this Motion.
5. The Defendant’s interview/ statement is not for purposes of substantial assistance to the
United States in the investigation and/or prosecution of other persons.
6. According to the United States Marshals Service, the Warden of the Salem County (New
Jersey) Detention Center does not obj ect to the above procedure.
7. The parties respectfully request that the Defendant’s sentencing not be scheduled before
November 2007 in order to provide sufficient time to arrange for the above-described
interview/statement.
2

Case 1 :07-cr-00025-JJF Document 34 Filed O9/24/2007 Page 3 of 3
Wherefore the United States and the Defendant respectfully request that this Honorable
Court authorize the United States and its employees and defense counsel, Edson Bostic, Esq.,
access to federal detainee Defendant Robert Cottman, IH in Salem County (N ew Jersey)
Detention Center so that the Defendant may participate in a videotaped statement/interview that
the United States and its employees may use for educational, promotional, deterrent and like
purposes in support of law enforcement initiatives, including Operation FED UP, Proj ect Safe
Neighborhoods, and Operation Disarm.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney

dson Bostic, Esq. obert J. Prett an Q-7 fj -{/7
Attorney for Robert Cottman, III Assistant U.S. Attorney
3

Case 1 :07-cr—OOO25—JJF Document 34-2 Filed O9/24/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. g Criminal Action No. 07-25-JJF
ROBERT COTTMAN, III, {
Defendant. g
ORDER AUTHORIZING THE UNITED STATES
AND DEFENSE COUNSEL ACCESS TO FEDERAL DETAINEE
FOR A VIDEOTAPED INTERVIEW FOR EDUCATIONAL, PROMOTIONAL
AND DET ERRENCE PURPOSES
For the above stated reasons, it is hereby Ordered this _ day of September, 2007
that:
The United States and its employees and defense counsel, Edson Bostic, Esq., may
have access to federal detainee Defendant Robert Cottman, III at Salem County (N ew
Jersey) Detention Center on a date and time agreed to by the parties and officials at the
Salem County Detention Center so that the Defendant may paiticipate in a videotaped
statement/interview that the United States and its employees may use for educational,
promotional, deterrent and related purposes in support of law enforcement initiatives,
including Operation FED UP, Proj ect Safe Neighborhoods, and Operation Disarm.

United States District Court Judge
District of Delaware