Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cr-00109-GMS

Document 22

Filed 08/17/2006

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. KRISTEN NOWACK, Defendant, : : : : : : : : :

Criminal Action No. 05-109-GMS

MOTION FOR CONTINUANCE OF SENTENCING HEARING Defendant, Kristen Nowack, by and through his undersigned counsel, Christopher S. Koyste, hereby moves the Court for an order continuing the September 7, 2006 sentencing hearing to October 11, 2006 at 9:00 a.m. Counsel submits the following in support thereof: 1. Sentencing in this action is currently scheduled for September 7, 2006. Council from

the Government and the Defense was contacted yesterday by the United States Probation Office concerning new information which the Defense needs additional time to investigate and issue a response. Thus, Ms. Nowack seeks a continuance of the sentencing hearing. 2. AUSA Beth Moskow-Schnoll and USPO Jean M. Lubinsky do not oppose this request

for rescheduling of the sentencing hearing to October 11, 2006 at 9:00 a.m. WHEREFORE, Ms. Nowack respectfully requests the Court to continue the sentencing hearing to October 11, 2006 at 9:00 a.m.

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Kristen Nowack DATED: August 17, 2006

Case 1:05-cr-00109-GMS

Document 22

Filed 08/17/2006

Page 2 of 2

CERTIFICATE OF SERVICE Undersigned counsel certifies that his Motion for Continuance of Sentencing Hearing is available for public viewing and downloading and was electronically delivered on August 17, 2006 to:

Beth Moskow-Schnoll, Esq. Assistant United States Attorney 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Kristen Nowack