Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00003-JJF

Document 23

Filed 03/07/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. JUDITH A. MAGRASS, Defendant.

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Criminal Action No. 07-03-JJF

DEFENDANT'S MOTION FOR CONTINUANCE OF SENTENCING Defendant, Judith Magrass, by and through her undersigned counsel, Edson A. Bostic, hereby moves the Court for an Order continuing the sentencing hearing in this case. In support of this motion, the defense submits as follows: 1. 2. Ms. Magrass is scheduled for sentencing on April 18, 2008, at 11:00 a.m. The Presentence Investigation interview was conducted on January 16, 2008. At

that time, defense counsel was to provide additional documentation with regards to Ms. Magrass's medical and psychological history. 3. Defense counsel respectfully requests, that Ms. Magrass's sentencing be continued

30 days from the current scheduled sentencing date of April 18, 2008, to allow defense counsel to continue to get all necessary paperwork to Martin P. Durkin, United States Probation Officer for preparation of the Presentence Report (PSR). Furthermore, this will allow the parties adequate time to review the initial draft of the PSR and make any objections or corrections to the report, if necessary.

Case 1:07-cr-00003-JJF

Document 23

Filed 03/07/2008

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4.

Assistant United States Attorney, Shannon T. Hanson, counsel handling this case for

the government, has no objection to the defense's continuance request. WHEREFORE, Ms. Magrass respectfully requests that this Court issue an Order postponing the Sentencing Hearing for at least 30 days.

Respectfully submitted,

/s/ Edson A. Bostic, Esquire Federal Public Defender Attorney for Judith A. Magrass

One Customs House 704 King Street, Suite 110 Wilmington, DE 19801 (302) 573-6010 [email protected]

Dated: March 7, 2008

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Case 1:07-cr-00003-JJF

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Filed 03/07/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. JUDITH A. MAGRASS, Defendant.

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Criminal Action No. 07-03-JJF

ORDER In response to Ms. Magrass' Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ________ day of ____________________, 2008, that Defendant's sentencing hearing is rescheduled for the _______ day of _________________, 2008 at ________ a.m./p.m.

Honorable Joseph J. Farnan, Jr. United States District Court