Free Motion to Continue - District Court of Delaware - Delaware

Case 1:06-cr-00006-GMS

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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.

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 was recently in a car accident and broke a bone in her neck.

She temporarily is not available 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. 2. AUSA Douglas McCann, who is handling the case for the government, does not oppose this request for a continuance. 3. 4. Mr. Baul was released in the above matter and has no objection to the continuance. Defense counsel will be available anytime in September with the exception of September 11-13th, and September 19, 2006.

Case 1:06-cr-00006-GMS

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Filed 07/12/2006

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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 this Court re-schedule the evidentiary hearing in this matter for a time convenient to the Court and counsel in September. Respectfully Submitted,

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

Date: July 12, 2006

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

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 July 12, 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.

Honorable Kent A. Jordan United States District Court