Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00006-GMS

Document 31

Filed 09/27/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RASHAN BAUL, Defendant.

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Criminal Action No. 06-06-KAJ

MOTION FOR CONTINUANCE OF EVIDENTIARY HEARING Defendant, Rashan Baul, by and through his undersigned counsel, Eleni Kousoulis, hereby moves this Court for an order re-scheduling the evidentiary hearing in this case. As grounds for this motion, the defense submits as follows: 1. Undersigned counsel had surgery on her right hand on August 28, 2006. Given that

defense counsel is right-handed, she is impaired in writing at the present time, which could interfere with her ability to effectively represent Mr. Baul at his pending evidentiary hearing. Therefore, defense counsel respectfully requests that the evidentiary hearing in this matter be continued until anytime after October 16, 2006, to allow her hand proper time in which to heal. 2. AUSA Douglas McCann, who is handling the case for the government, does not

oppose this request for a continuance. 3. Mr. Baul was released in the above matter and has no objection to the continuance.

Case 1:06-cr-00006-GMS

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Filed 09/27/2006

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4.

After speaking with the Court's chambers, defense counsel was informed that the

Court is available to hold this hearing on October 18, 2006 at 9:30 a.m. All parties and witnesses are available at this date and time. 5. The parties agree that all time up until the new hearing date will be excludable under

the Speedy Trial Act. WHEREFORE, for all the above reasons, the defense respectfully requests that the Court re-schedule the evidentiary hearing in this matter for October 18, 2006 at 9:30 .a.m. Respectfully Submitted,

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

Date: September 27, 2006

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Case 1:06-cr-00006-GMS

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Filed 09/27/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RASHAN BAUL, Defendant.

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Criminal Action No. 06-06-KAJ

CERTIFICATE OF SERVICE Undersigned counsel certifies that a copy of Defendant Motion for Continuance of Evidentiary Hearing is available for public viewing and downloading and was electronically delivered on September 27, 2006, to:

Douglas McCann, 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 St., Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Rashan Baul

Case 1:06-cr-00006-GMS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

RASHAN BAUL Defendant.

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Criminal Action No. 06-06-KAJ

ORDER The Court having considered Defendant Rashan Baul's Motion For Continuance of Evidentiary Hearing and good cause having been shown therefore, IT IS HEREBY ORDERED this _______ day of ___________________, 2006 that the Evidentiary Hearing in this case be re-scheduled for the ______ day of _______________, 2006 at _________ a.m./p.m.

Honorable Kent A. Jordan United States District Court