Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:08-cr-00059-GMS

Document 22

Filed 07/18/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. THOMAS S. PENDLETON, Defendant. : : : : : : :

Criminal Action No. 08-59-GMS

DEFENDANT PENDLETON'S PROPOSED ORDERS OF COURT AND NOW comes the defendant, Thomas Pendleton, by his attorney Eleni Kousoulis of the Federal Public Defender's Office, and files these proposed Orders of Court, reflecting the District Court's oral rulings at the status conference conducted earlier today. 1. The first proposed order grants defendant's motion for bill of particulars, and

directs that the bill be filed on or before July 31, 2008. 2. The second proposed order denies defendant's motion for summary of expert

testimony; the submission of this proposed order does not reflect defendant's abandonment of his claim that he is entitled to the expert summary. 3. The third proposed order directs that defendant's pre-trial motions be filed on or

before Monday, August 18, 2008, and that the government's responsive brief be filed on or before Tuesday, September 2, 2008; in addition, defendant requests that he be permitted to file a reply brief on or before Tuesday, September 9, 2008.

Respectfully submitted, /s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender Federal Public Defender's Office 704 King Street, Suite 110 Wilmington, DE 19801 (302) 573-6010 [email protected] Attorney for Defendant Thomas S. Pendleton

Date: July 18, 2008

Case 1:08-cr-00059-GMS

Document 22-2

Filed 07/18/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. THOMAS S. PENDLETON, Defendant. : : : : : : : : :

Criminal Action No. 08-59-GMS

ORDER OF COURT

AND NOW, this ________ day of July, 2008, upon consideration of Defendant's Motion for Bill of Particulars, it is hereby ordered that the motion is GRANTED. On or before July 31, 2008, the government shall file a bill of particulars providing the following information: 1. For the period from on or about January 28, 2008, to on or about March 10, 2008, identify the states in which it is alleged that defendant unlawfully failed to register as a sex offender and/or failed to update registration as a sex offender. 2. For each state identified in answer to Item 1, identify the prior conviction or convictions which are alleged to trigger defendant's duty to register and/or update registration. 3. For each state identified in answer to Item 1, identify the episodes of foreign or interstate travel ­ by date, state of departure and state of arrival ­ which are alleged to trigger defendant's duty to register and/or update registration. BY THE COURT,

_________________________________ Honorable Gregory M. Sleet Chief Judge, United States District Court

Case 1:08-cr-00059-GMS

Document 22-3

Filed 07/18/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. THOMAS S. PENDLETON, Defendant.

: : : : : : : : :

Criminal Action No. 08-59-GMS

ORDER OF COURT

AND NOW, this _______ day of July, 2008, upon consideration of defendant's motion for summary of expert testimony, it is hereby ordered that the motion is DENIED.

BY THE COURT, ____________________________ Honorable Gregory M. Sleet Chief Judge, United States District Court

Case 1:08-cr-00059-GMS

Document 22-4

Filed 07/18/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. THOMAS S. PENDLETON, Defendant.

: : : : : : : : :

Criminal Action No. 08-59-GMS

ORDER OF COURT

AND NOW, this _________ day of July, 2008, it is hereby ordered that defendant's pre-trial motions, with supporting briefs, shall be filed on or before Monday, August, 18, 2008. The government's responsive briefs shall be filed on or before Tuesday, September 2, 2008. Defendant may file a reply brief on or before Tuesday, September 9, 2008.

BY THE COURT,

_________________________________ Honorable Gregory M. Sleet Chief Judge, United States District Court