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

Case 1:07-cr-00009-GIVIS Document 12 Filed O3/O9/2007 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action No. 07-09-GMS
CLAVEN ANDERSON
Defendant.
MOTION TO EXTEND TIME TO FILE PRE-TRIAL MOTIONS
Defendant Claven Anderson, by and through his undersigned counsel, Eleni Kousoulis,
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 the Defendant submits as follows:
1. Pre—trial motions in this case are due by March 9, 2007.
2. On March 6, 2007, defense counsel and counsel for the govemment were made aware
for the first time that the defendant was interviewed by law enforcement officers in regard to this
case and that the defendant made a statement. The case agent for this case is in the process of
preparing a report regarding the interview ofthe defendant. Defense counsel requires time to review
the statement allegedly made by the defendant and to discuss factors relating to the statement and
to the taking of the statement with the defendant before it can be detemiined what, if any, pre—trial
motions need to be filed in this case.
3. The defendant respectfully requests an extension of time of one month in which to
file any pre-trial motions to allow defense counsel adequate time to review the defendant’s alleged

Case 1:07-cr-00009-GIVIS Document 12 Filed O3/O9/2007 Page 2 of 3
statement with the defendant once it is received from the govemment.
4. AUSA Sophie Bryan, counsel for the govemment, has no objection to this motion for
an extension of time in which to tile pre—trial motions.
WHEREF ORE, it is respectfully requested that the time for Defendant to file pre-trial
motions be extended until anytime after April 10, 2007.
Respectfully Submitted,
. ` I ’\ `
Eleni Kousoulis, Esquire
Assistant Federal Public Defender
704 King Street, Suite 1 10
Wilmington, Delaware 19801
(302) 573-6010
Attorney for Defendant Claven Anderson
Dated: March 9,2007
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Case 1:07-cr-00009-GIVIS Document 12 Filed O3/O9/2007 Page 3 of 3
CERTIFICATE OF SERVICE
Undersigined counsel certifies that two copies ofDefendant’s Motion to Extend Time to File
Pretrial Motions were hand delivered on March 9, 2007, to a box designated for the U.S. Attomey's
Office located in the U.S. District Court C1erk's Office addressed to:
Sophie Bryan, Esquire
U.S. Attomey’s Office
The Nemours Building
1007 Orange Street, Suite 700
Wilmington, DE 19801
Eleni Kousoulis, Esquire
Assistant Federal Public Defender
704 King Street Suite 110
Wilmington, DE 19801
(302) 573-6010
Attorney for Defendant Claven Anderson
DATED: March 9, 2007