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

Case 1:06-cr-00008-SLR

Document 12

Filed 05/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RICHARD REID, Defendant.

: : : : : : : : : :

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 May 19, 2006. Defense counsel requires additional time to sufficiently review the discovery in the

present case and additional time to meet with Mr. Reid to discuss how the defense is going to proceed, before it can be determined what, if any, pre-trial motions need to be filed. 3. Defense counsel will be out of the office from May 30, 2006 through June 2, 2006,

and out of the office from June 21, 2006 through June 27, 2006, and respectfully requests that the time in which to file pre-trial motions be extended to anytime after July 6, 2006. This will give counsel adequate time to review the discovery and to meet with and discuss the case with Mr. Reid. 4. The parties have agreed that any additional time given in which to file pre-trial

Case 1:06-cr-00008-SLR

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motions will be excludable under the Speedy Trial Act. 5. AUSA Dave Hall, the attorney handling the case for the government, does

not object to the enlargement of time. 6. It is respectfully requested that the time for Defendant to file pre-trial motions be

extended to anytime after July 6, 2006.

Respectfully Submitted,

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

Dated: May 18, 2006

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Filed 05/18/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RICHARD REID, Defendant.

: : : : : : : : : :

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 to Extend Time to File Pretrial Motions is available for public viewing and downloading and was electronically delivered on May 18, 2006, to:

Dave Hall, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

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

Case 1:06-cr-00008-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RICHARD REID, Defendant.

: : : : : : : : :

Criminal Action No. 06-08-KAJ

ORDER Having considered Defendant's Motion to Extend Time to File Pretrial Motions, IT IS HEREBY ORDERED this day of day of , 2006, that

Defendant Reid's pretrial motions shall be due on the , 2006.

Honorable Kent A. Jordan United States District Court