Free Motion for Leave to File - District Court of Delaware - Delaware

Case 1:06-cr-00006-GMS

Document 9

Filed 03/16/2006

Page 1 of 2

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FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, v. RASHAN J. BAUL, Defendant.
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Cr.A. No. 06-06-KAJ

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MOTION TO PERMIT NON-ELECTRONIC FILING OF MOTION TO WITHDRAW
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COMES NOW the defendant, above, by and through counsel, Joe

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Kurley, who moves for leave of the Court to file a Motion to Withdraw
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Counsel in what will be termed the "traditional" fashicn, and in

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support of such application, represents that counsel has not yet had
t h a opportunity tc undergo the significant transition from t h "tradi~
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tional" mode of filings to the "state-of-the-art' no62 tc--: >ow exists. The transition will require counsel to attend a trainiz? szssion, counsel's secretary to attend a training session, and the overhaul of counsel's operations including the purchase of new equipment in order

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to accommodate the transition. WHEREFORE, leave of the Court is sought to file the Motion as sought herzia.

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Dated:

March 16, 2006

Case 1:06-cr-00006-GMS

Document 9

Filed 03/16/2006

Page 2 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA,
v.

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Cr.A. No. 06-06-KAJ

RASHAN J. BAUL, Defendant.

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CERTIFICATE OF SERVICE

I hereby certify that twc ccpiss of the foragoing Motion to Permit Non-Electronic Filing of Motion ta Withdraw were served upon the following person on Narch 16, 2006: Douglas E. McCann U.S. Attorney's Office Suite 700 1007 Orange Street Kilmington, DE 19801

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Dated:

March 16, 2006