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

Case 1:08-cr—00054-GIVIS Document 31 Filed 05/30/2008 Page 1 of 4
Peter A. Levin
Attorney at Law
1927 Hamilton Street 811 Church Road
Philadelphia, PA 19130 Suite iO5
(215) 563-3454 Cherry Hill, N.J. 08002
Fax (215) 563-3371
May 29, 2008
Clerk of Court
United States District Court for the District of Delaware
J. Caleb Boggs Federal Building, Fourth Floor (V ..,. I
844 North King Street § ‘
Wilmington, DE 19801 °’° ‘’‘i i
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BE. USA v. Torres 08-54-2-GMS **;;,1
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Dear Clerk of Court: N
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Enclosed please find original of Motion in the above matter. r ,0,,,Q
Thank you.
Sincerely, Z
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Peter A. Levin "

Case 1 :08-cr—00054-GIVIS Document 31 Filed 05/30/2008 Page 2 of 4
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
ORDER
AND NOW, this day of 2008, upon consideration of the
Defendants 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._____; ______ ____________

Case 1 :08-cr—00054-GIVIS Document 31 Filed 05/30/2008 Page 3 of 4
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 I
MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO FILE PRE-
TRIAL MOTIONS
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—TriaI Motions. In
support there of he asserts the following:
1. Defendant is charged with wire conspiracy to commit aggravated identity theft and
related charges.
2. On May 22, 2008, the defendant was arraigned and entered a plea of not guilty to
the above-captioned indictment.
3. Counsel as of this date has not received any discovery on the case.
4. The defendant is incarcerated and speaks limited English.
5. ln order to properly prepare Pre-Trial Motions on the above matter, counsel needs
additional time to review the discovery in this matter when it is received and go over it
with the defendant.
WHEREFORE, Defendant , respectfully requests this Honorable Court to enter
an Order granting an Enlargement of Time to file Pre-Trial Motions within thirty days.
Respyectfully submitted,
if I} ·
Attorney for Defendant

Case 1 :08-cr—00054-GMS Document 31 Filed 05/30/2008 Page 4 of 4
CERTIFICATE OF SERVICE
Peter A. Levin, Esquire, hereby certifies that a true and correct copy of the within
Motion has been sen/ed upon by First Class Mail to:
Keith M. Rosen, Esquire
Assistant United States Attorney
1007 Orange Street
Suite 700
Wilmington, DE 19899-2046
.·.· "* xl
F xx
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Peter A. Leigh, Esquire
1927 Hamilton Street
Philadelphia, PA 19130
Date: 5/29/08

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