Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00020-GMS

Document 22

Filed 08/30/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY FRIDAS, Defendant.

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Criminal Action No. 07-20-GMS

MOTION FOR CONTINUANCE OF SENTENCING Defendant, Anthony Fridas, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court for an Order continuing the sentencing hearing in this case. In support of the motion, the defense submits as follows: 1. 2. Mr. Fridas is currently scheduled for sentencing on September 18, 2007 at 9:30 a.m. Defense counsel will be out of the office attending a conference from September 16,

2007 through September 19, 2007, and therefore will be unavailable on September 18, 2007, the date that Mr. Fridas' sentencing is currently scheduled. In addition, defense counsel requires additional time to prepare for sentencing and additional time to review the Presentence Report (PSR) with Mr. Fridas to determine what, if any, objections to the PSR the defense wishes to make. As of August 30, 2007, Mr. Fridas had not yet received a copy of his PSR in this case, and defense counsel has not yet had the opportunity to review the PSR with Mr. Fridas. 3. Defense counsel respectfully requests that Mr. Fridas' sentencing be continued for

30 days to allow defense counsel time to adequately prepare for sentencing.

Case 1:07-cr-00020-GMS

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Filed 08/30/2007

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4.

AUSA Edmond Falgowski, the attorney handling this case for the government, has

no objection to the defense's continuance request. 5. 2007. WHEREFORE, Mr. Fridas respectfully requests that the Court continue the sentencing hearing in this matter to anytime after October 22, 2007. Respectfully Submitted, Any objections to the PSR will be filed by the defendant no later than October 5,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Anthony Fridas

DATED: August 30, 2007

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Case 1:07-cr-00020-GMS

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Filed 08/30/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY FRIDAS, Defendant.

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Criminal Action No. 07-20-GMS

ORDER

In response to Mr. Fridas' Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ________ day of ____________________, 2007, that Defendant's sentencing hearing be re-scheduled for the _______ day of _________________, 2007 at ________ a.m./p.m.

The Honorable Gregory M. Sleet United States District Court