Free Motion to Continue - District Court of Delaware - Delaware

Case 1 :07-cr-00003-JJF Document 17 Filed 09/20/2007 Page 1 of 4 I
. IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE
I UNITED STATES OF AMERICA, :
A · Prarniirn E I I
I v. Criminal Action No. 07 ~03 JIF
JUDITH MARGASS,
Defendant. ‘ : _
JOINT MOTION FOR CON TINUAN CE i
The United States of America, by and through Colm F. Comrolly, United States Attorney n
for the District of Delaware, and Shannon Thee Hanson, Assistant United States Attorney for the
District of Delaware, and Edson Bostic, Esq., counsel for the above-narned defendant, hereby
I move this Court to postpone trial in the above-captioned matter until a date certain after February
1, 2008, and for their reasons state as follows: "
I (1) On May 4, 2007, the Court held a status conference at which time the parties agreed
that a continuance to assess the defendant’s medical condition was appropriate. Thereafter, by
Order dated May 14, 2007, the Court granted the parties’ request for a postponement of trial.
That Order directed counsel to submit a joint letter on or before September 7, 2007 "as to the
.' current status of the defendant’s medical condition." D.I. 16. I i i
(2) On September 7, 2007, the parties submitted for the Court’s consideration the report q
of Allan M. Tepper, J.D., Psy.D., dated August 23, 2007. Having reviewed and discussed Dr.
p Tepper’s report, the parties requested that the Court schedule trial in this matter for a date no i
earlier than February l, 2008, consistent with the Court’s calendar. The parties noted their intent I
‘ to use the time to obtain additional medical records and to attempt a pre—trial resolution of this _ ;

Case 1 :07-cr-00003-JJF Document 17 Filed 09/20/2007 Page 2 of 4
matter.
(3) The Court conducted a status conference on September 19, 2007, at which time the
parties formalized their request for a postponement of trial. At the conference, the defendant
agreed to waive her right to a Speedy Trial in favor of postponing the trial until a date certain in
February, 2008. Defense counsel expressed his belief that the requested delay would be in the
defendant’s best interest.
(4) At the conclusion of the conference, the Court requested that the parties draft a
proposed order regarding the continuance in the trial date. The Order is attached hereto.
H WHEREFORE, the parties respectfully ask that the Court set a trial date in this matter for
a date certain in February, 2008. A proposed form of order is attached for the Court’s
` convenience. ` l `
- Respectfully submitted,
COLM F. CONNOLLY E
United States Attorney
I l _. (' Q ling
B §e—·>» ‘ A
- - ..1 on T. *‘ anson _
` . Assistant United States Attorney
1007 Orange Street, Suite 700
P.O. Box 2046 i
. _ Wihnington, Delaware 19899-2046 I A
Dated: September 20, 2007 I

A in _ Case 1 :07-cr-00003-.].11: Document 17 Filed 09/20/2007 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
. FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
l Plaintiff]
_ v. Criminal Action No. 07 —03 JJF
- JUDITH MARGASS,
Defendant. :
ormnk A A
Having conducted a September 19, 2007, status conference in the above—capti0ned case
and for the reasons stated in the parties’ Joint Motion for Continuance, E
‘ IT IS HEREBY ORDERED this _ day of , 2007, that the parties’
Joint Motion for Trial Continuance is GRANTED. `
The trial is this matter is set for February ___, 2008.
The pretrial conference in this matter is set for , 2008.
A e 7
- I I UNITED STATES DISTRICT JUDGE ,

-Case‘1 :07-cr-00003-JJF Document 17 Filed 09/20/2007 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE U
UNITED STATES OF Al\/IERICA, :
piamaa; E
v. Criminal Action No. 07 -03 JJF
JUDITH MARGASS, _ _
Defendant. :
CERTIFICATE OF SERVICE Z
I, Shannon T. Hanson, hereby certify that on September 20, 2007, I caused the foregoing
Joint Motion for Continuance and Proposed Order to be served on the following counsel in the 1
manner indicated:
A BY CM/ECF
Edson Bostic, Esquire
Federal Public Defender's Office l
First Federal Plaza, Suite 110 2
704 King Street “
Wilmington, DE 19801 Q
· (302) 573-6010 l
Email: [email protected] ”
Attorney for Judith Margass J
‘ ’ ··· 4 .. . x

_ _ •,_H O SOI] i