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

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 J. BAUL, Defendant.

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Criminal Action No. 06-06-KAJ

MOTION TO EXTEND TIME TO FILE PRETRIAL MOTIONS Defendant Rashan J. Baul, by and through his undersigned counsel, Penny Marshall, 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. Per an order dated April 7, 2006, the Federal Public Defender's Office was appointed to represent Mr. Baul in the present case when former counsel Joseph Hurley withdrew. 2. Counsel received Discovery on April 7, 2006 and needs additional time to become familiar with the case and to determine which, if any, pretrial motions need to be filed. 3. The parties have agreed that any additional time given in which to file pretrial motions will be excludable under the Speedy Trial Act.

4.

Douglas McCann, Esquire, the attorney handling the case for the government, does

Case 1:06-cr-00006-GMS

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not object to the enlargement of time. 5. It is respectfully requested that the time for Defendant to file pretrial motions be

extended three weeks from April 7, 2006.

Respectfully Submitted,

/s/ Penny Marshall, Esquire Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801

Dated: April 13, 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 April 13, 2006 to:

Douglas E. McCann, Esquire Assistant U.S. Attorney United States Attorney's Office 1007 Orange Street, Suite 700 Wilmington, DE 19801

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

DATED:

April 13, 2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. RASHAN J. BAUL, Defendant.

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Criminal Action No. 06-06-KAJ

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

Baul's pretrial motions shall be due on the _________ day of __________________, 2006.

Honorable Kent A. Jordan United States District Court