Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00141-SLR

Document 18

Filed 06/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. JESUS SALINAS-ESCAMILLA, Defendant.

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Criminal Action No. 06-141-SLR

MOTION FOR CONTINUANCE OF SENTENCING Defendant, Jesus Salinas-Escamilla, 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. Salinas-Escamilla is scheduled for sentencing on June 6, 2007, at 8:30 a.m. Defense counsel, Eleni Kousoulis, was assigned this case on May 29, 2007. Ms.

Kousoulis took over the case from attorney Christopher Koyste. Ms. Kousoulis has not had the opportunity to meet with Mr. Salinas-Escamilla to discuss the case and any sentencing issues with him. Ms. Kousoulis respectfully requests a brief continuance of the Sentencing Hearing in this case to allow her the opportunity to meet with Mr. Salinas-Escamilla and to prepare for sentencing. 3. AUSA Robert Kravetz, the attorney handling this case for the government, does not

oppose this request for a continuance. 4. Defense counsel spoke to the Court's chambers and was informed that the Court had

Case 1:06-cr-00141-SLR

Document 18

Filed 06/04/2007

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available June 8, 2007 at 11:00 a.m. in which to hold the Sentencing Hearing in this matter. All parties are available at that date and time. WHEREFORE, Mr. Salinas-Escamilla respectfully requests that the Court continue the Sentencing Hearing in this matter to June 8, 2007 at 11:00 a.m. Respectfully Submitted,

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

DATED: June 4, 2007

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Case 1:06-cr-00141-SLR

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Filed 06/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. JESUS SALINAS-ESCAMILLA, Defendant.

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Criminal Action No. 06-141-SLR

ORDER In response to Mr. Salinas-Escamilla's Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ______day of ________________, 2007, that Defendant's Sentencing Hearing is re-scheduled for the ______ day of _______________, 2007 at _________ a.m./p.m.

The Honorable Sue L. Robinson United States District Court