Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00008-SLR

Document 27

Filed 01/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RICHARD REID, Defendant.

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Criminal Action No. 06-08-KAJ

MOTION FOR CONTINUANCE OF TRIAL Defendant, Richard Reid, through undersigned counsel, Eleni Kousoulis, hereby moves this Honorable Court for an order re-scheduling the trial in this matter. In support of the motion, the defense submits as follows: 1. 2. This matter is currently scheduled for a 2-day trial beginning on January 17, 2007. Defense counsel requires additional time to investigate and prepare for trial and does

not anticipate being ready to proceed to trial on January 17, 2007. 3. In order for defense counsel to effectively represent Mr. Reid, a short continuance

of three weeks is needed to complete needed investigation and preparation. 4. AUSA Sophie Bryan, the attorney handling this case for the government, does not

oppose the defense's request for a continuance.

Case 1:06-cr-00008-SLR

Document 27

Filed 01/04/2007

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WHEREFORE, the defense respectfully requests that the Court re-schedule the trial in this matter for a date in February, 2007, anytime after February 6, 2007.1 Respectfully submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Richard Reid

DATED: January 4, 2007

This trial is anticipated to last no longer than 2 days. All parties are available anytime in February after February 6, 2007, with the exception of the following dates: the government is not available on February 13, 2007, and defense counsel is not available February 20 and 21, 2007.
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Case 1:06-cr-00008-SLR

Document 27

Filed 01/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v RICHARD REID, Defendant.

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Criminal Action No. 06-08-KAJ

CERTIFICATE OF SERVICE The undersigned attorney for defendant Richard Reid hereby certifies that a copy of Defendant's Motion for Continuation of Trial is available for public viewing and downloading and was electronically delivered on January 4, 2007, to: Sophie Bryan, Esquire Assistant U.S. Attorney United States Attorney's Office 1007 Orange Street, Suite 700 Wilmington, DE 19801

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, DE 19801 Attorney for Defendant Richard Reid

Case 1:06-cr-00008-SLR

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Filed 01/04/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. RICHARD REID, Defendant.

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Criminal Action No. 06-08-KAJ

ORDER Having considered Defendant Reid's Motion for Continuance of Trial, IT IS HEREBY ORDERED this day of , 2007, that Defendant Reid's trial in

this matter be rescheduled for the ________ day of _______________________, 2007.

Honorable Sue L. Robinson United States District Court