Free Motion for Extension of Time to File - District Court of Delaware - Delaware

V Wl Case 1:08-cr—00054-GIVIS Document 36 Filed 07/10/2008 Page1 of3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
V.
CRIMINAL NO. 08-54-2 GMS
JOSE A. TORRES
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO
FILE PRE-TRIAL MO'I'lONS
Defendant, JOSE A. TORRES, by his attorney, Peter A. Levin, respectfully
moves this Honorable Court to enter an Order pursuant to Rule 45 (B) of the Federal
Rules of Criminal Procedure, enlarging time within which to file Pre-Trial Motions. In
support there of he asserts the following:
1. Defendant is charged with wire conspiracy to commit aggravated identity theft and
related charges. On May 22, 2008, the defendant was arraigned and entered a plea
of not guilty to the above—captioned indictment.
2 Pre-trial motions are due on July 11, 2008.
3. Plea discussions are under way with the government but will not be concluded until
mid August due to vacation schedules of counsel. lt is anticipated that no pre trial
motions will be filed but in an abundance of caution counsel is requesting an
extension of time to file pre trial motions until August 20 in the event that pre trial
motions are necessary.
4. The government is not opposed to the extension of time.
WHEREFORE, Defendant , respectfully requests this Honorable Court to enter
an Order granting an Enlargement of Time to file Pre-Trial Motions if necessary by
August 20, 2008.
Respectfully submitted, Qf
J `“’if · -¢ii=—. _ - ..,._ . M =l l-la Ul lll? fill?
Peter A. Levin A J W i_`M $m_§
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_ Case 1:08-cr—00054-GMS Document 36 Filed 07/10/2008 Page 2 of 3
CERTIFICATE OF SERVICE
Peter A. Levin, Esquire, hereby certifies that a true and correct copy of the within
Motion has been served upon by First Class Mail to:
Keith M. Rosen, Esquire
Assistant United States Attorney
1007 Orange Street
Suite 700
Wilmington, DE 19899-2046
.·»` . , _·é,_ C _,
{3.... Q ».. ._.. .
E>E?&"/-TESQTEEJLEYE
1927 Hamilton Street
Philadelphia, PA 19130
Date: 7/8/08

N , Case 1:08-cr—00054-GIVIS Document 36 Filed 07/10/2008 Page 3 of 3
IN THE UNITED STA'I'ES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
V.
CRIMINAL NO. 08-54-2 GMS
JOSE A. TORRES
ORDER
AND NOW, this day of 2008, upon consideration of the
Defendant’s Unopposed Motion for Enlargement of Time within which to file Pre-Trial
Motions it is hereby ORDERED and DECREED that said Motion is GRANTED.
BY THE COURT:
J.___ _____________ ____ ____

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