Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07—cr—00024-SLR Document 17 Filed 07/17/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
>
Plaintiff, )
>
v. ) Crim. No.: 07-24-SLR
)
CHRISTOPHER M. KRAUSS, )
>
Defendant. )
NOTICE OF MOTION
TO: Douglas McCann, AUSA Martin Durkin, Pre—Sentence
U.S. Department of Justice 844 King Street
l007 Orange Street, #700 Lock Box 39
P. O. Box 2046 Wilmington, DE l980l
Wilmington, DE l9899
PLEASE TAKE NOTICE the attached Motion for Continuance will be
heard by The Honorable Sue L. Robinson at the convenience of Court
and counsel.
Edmung Danielziygns — 0881
Attorney for Defendant
l526 Gilpin Avenue
P. O. Box 579 _
Wilmington, Delaware l9899
(302) 777~5698
Dated: July l7, 2007

Case1:07—cr—00024-SLR Document17 Filed 07/17/2007 Page2of4
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. ; Crim. No.: 07-24-SLR ·
CHRISTOPHER M. KRAUSS, ;
Defendant. g
MOTION FOR CONTINUANCE OF SENTENCING DATE
l. The above captioned. matter has been scheduled. for
Sentencing before Your Honor on Thursday, August l6, 2007 at 4:30
p.m.
2. Defendant’s brother, who had been gravely ill for some
time, passed away on Sunday, July 8, 2007.
3. Due to the illness of his brother, Defendant had been
unable to complete the paperwork required for Martin Durkin of
Federal Probation and Parole.
4. Due to these circumstances, Defendant, through counsel,
respectfully requests a 30 day continuance of the sentencing to
allow Defendant to prepare the needed paperwork for Mr. Durkin.
5. Neither the Government nor Mr. Durkin have any objection
to this request.
/%£;\//
pf vtnf g
IE mund D'a.ni' ii S — 0881
Attorney for Defendant
l526 Gilpin Avenue
Wilmington, Delaware 19806
Dated: July l7, 2007

Case 1:07—cr—00024-SLR Document 17 Filed 07/17/2007 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
UNITED STATES OE AMERICA, )
Plaintiff, g
v. ; Crim. No.: 07-24-SLR
CHRISTOPHER M. KRAUSS, §
Defendant. 3
QB.DE.R
GOOD CAUSE APPEARING therefore, it is hereby Ordered that
Sentencing in the above captioned matter has been rescheduled to

Dated:

Case 1:07—cr—00024-SLR Document 17 Filed 07/17/2007 Page 4 of 4
AFFIDAVIT OF MAILING
I, Donna L. Hendricks, secretary for Edmund Daniel Lyons,
Esquire hereby certifies that on this 17th day of July, 2007, I
caused. a copy· of the attached: Motion. For Continuance of
Sentence, to be delivered electronically, and by first—class mail
to the following:
Douglas McCann, AUSA
1007 Orange Street, #700
P. O. Box 2046
Wilmington, DE 19899
Martin Durkin, Pre—Sentence
844 King Street
Lock Box 39
Wilmington, DE 19801
The document is available for public viewing and downloading.
Donna L. He ricks