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

Case 1:06-cr-00008-SLR

Document 16

Filed 07/12/2006

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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 TO EXTEND TIME TO FILE PRETRIAL MOTIONS Defendant Richard Reid, 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 pretrial motions may be filed. In support of this motion the Defendant submits as follows: 1. 2. Pre-trial motions for this case are due by July 14, 2006. Undersigned counsel was recently in a car accident and broke a bone in her neck.

She temporarily is not able to appear in Court or to complete written work on the client's behalf. It is expected that she will return to work after about a month's time. 3. AUSA David Hall, counsel for the government, does not oppose the defense's request for an extension. 4. 5. Mr. Reid has been advised of the situation and request that the extension be granted. The defense agrees to waive, pursuant to the Speedy Trial Act, any additional time

given in which to file pre-trial motions.

Case 1:06-cr-00008-SLR

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Filed 07/12/2006

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WHEREFORE, it is respectfully requested that the time for Defendant to file pre-trial motions be extended and be due by August 18, 2006.

Respectfully Submitted,

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

Dated: July 12, 2006

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Case 1:06-cr-00008-SLR

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Filed 07/12/2006

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CERTIFICATE OF SERVICE Undersigned counsel certifies that a copy of Defendant's Motion to Extend Time to File Pretrial Motions is available for public viewing and downloading and was electronically delivered on July 12, 2006. David Hall Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

/s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street Suite 110 Wilmington, DE 19801 (302) 573-6010

Case 1:06-cr-00008-SLR

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Filed 07/12/2006

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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's Motion to Extend Time to File Pretrial Motions, IT IS HEREBY ORDERED this Reid's pretrial motions shall be due on the day of day of , 2006, that Defendant , 2006.

Honorable Kent A. Jordan United States District Court