Free Motion to Continue - District Court of Delaware - Delaware

Case 1:05-cr-00107-SLR

Document 34

Filed 10/17/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

MICHAEL R. HENRY Defendant.

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Criminal Action No. 05-107-SLR

MOTION FOR CONTINUANCE OF REVOCATION HEARING Defendant, Michael R. Henry, by and through his undersigned counsel, Keir Bradford, hereby moves this Court for an Order continuing his Revocation Hearing in this case. In support of the motion, the defense submits as follows: 1. A Revocation Hearing is currently scheduled for October 23, 2007 at 3:00 p.m. in

the above-captioned matter. 2. The basis for this alleged violation of supervised release are new criminal charges

currently pending against Mr. Henry. The case number for the new criminal charges is 07-129SLR. 3. Mr. Henry requests that his Revocation Hearing be continued until after his

pending case (07-129-SLR), which form the basis of his alleged violation of supervised release, is resolved. 4. Assistant United States Attorney Christopher Burke, who is handling this case

for the government, has no objection to the defense's request for a continuance.

Case 1:05-cr-00107-SLR

Document 34

Filed 10/17/2007

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WHEREFORE, Mr. Henry respectfully requests that his Revocation Hearing be continued until the open criminal charges pending against him are resolved.

Respectfully Submitted,

/s/ Keir Bradford, Esquire Assistant Federal Public Defender One Customs House 704 King Street, Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Michael Henry

Dated: October 16, 2007

Case 1:05-cr-00107-SLR

Document 34

Filed 10/17/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

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Criminal Action No. 05-107-SLR

MICHAEL HENRY, Defendant.

CERTIFICATE OF SERVICE Undersigned counsel certifies that a copy of Defendant's Motion for Continuance of Violation of Supervised Hearing is available for public viewing and downloading and was electronically delivered on October 16, 2007, to: Christopher J Burke, Esquire Assistant U.S. Attorney 1007 Orange Street Suite 700, P.O. Box 2046 Wilmington, DE 19899-2046

/s/ Keir Bradford, Esquire Assistant Federal Public Defender 704 King St., Suite 110 Wilmington, Delaware 19801 Attorney for Defendant Christopher J. Burke