Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cr-00109-GMS

Document 20

Filed 06/28/2006

Page 1 of 3

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 her undersigned counsel, Christopher S. Koyste, hereby moves the Court for an order continuing the June 30, 2006 sentencing hearing to a date in September 2006. Counsel submits the following in support thereof: 1. Sentencing in this action is currently scheduled for June 30, 2006. The Defense seeks

a continuance to obtain additional information that will allow the parties fully address all sentencing issues in this action. 2. AUSA Beth Moskow-Schnoll and USPO Jean M. Lubinski do not oppose this request

for rescheduling of the sentencing hearing. WHEREFORE, Ms. Nowack respectfully requests the Court to continue the sentencing hearing to a date in September 2006.

Case 1:05-cr-00109-GMS

Document 20

Filed 06/28/2006

Page 2 of 3

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, ESQUIRE Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 Email: [email protected] Attorney for Defendant Kristen Nowack

DATED: June 28, 2006

Case 1:05-cr-00109-GMS

Document 20

Filed 06/28/2006

Page 3 of 3

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 June 28, 2006 to:

Beth Moskow-Schnoll, AUSA United States Attorney's Office 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ Christopher S. Koyste CHRISTOPHER S. KOYSTE, AFPD Federal Public Defender's Office 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 Email: [email protected] Attorney for Defendant Kristen Nowack