Free Motion to Continue - District Court of Delaware - Delaware

Case 1:08-cr-00058-SLR

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Filed 06/12/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM HARRIS, Defendant.

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Criminal Action No. 08-58-SLR

MOTION FOR CONTINUANCE OF EVIDENTIARY HEARING The Defendant, William Harris, by and through his counsel, Luis A. Ortiz, Esquire, hereby moves the Court for an Order continuing the evidentiary hearing in this case. In support of the motion, the defense submits as follows: 1. 2. An evidentiary hearing in this matter is scheduled for June 23, 2008 at 10:00 a.m. The government and defense counsel are attempting to negotiate a non-trial

disposition of this matter and need additional time to complete these negotiations. Should the Defendant accept this offer, an evidentiary hearing will not be needed. 3. The Defendant respectfully requests that the evidentiary hearing in this matter be

continued for at least thirty days to allow him adequate time to consider any offer proposed by the government. 4. a continuance. Assistant United States Joseph Grubb, does not oppose the Defendant's request for

Case 1:08-cr-00058-SLR

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5.

The Defendant agrees to waive, pursuant to the Speedy Trial Act, any time between

June 23, 2008 and the rescheduled date for the hearing. WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the Defendant, William Harris, respectfully requests that the evidentiary hearing in this case be continued to any time after June 23, 2008.

Respectfully Submitted,

/s/ Luis A. Ortiz Luis A. Ortiz, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 302-573-6010 [email protected] Counsel for Defendant William Harris

Dated: June 12, 2008

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Case 1:08-cr-00058-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. WILLAIM HARRIS, Defendant.

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Criminal Action No. 08-48-SLR

ORDER In response to Defendant's Motion for Continuance of Evidentiary Hearing, this Court HEREBY ORDERS on this _________day of __________________, 2008, that Mr. Harris' evidentiary hearing be re-scheduled for the 11th day of August, 2008, at 9:00 a.m., and that the time from June 23, 2008 up to the day of the re-scheduled evidentiary hearing shall be excluded under the Speedy Trial Act (18 U.S.C. § 3161, et seq.).

HONORABLE SUE L. ROBINSON United States District Court