Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00143-JJF

Document 34

Filed 08/12/2008

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLES WARREN, Defendant.

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Criminal Action No. 07-143-JJF

DEFENDANT'S MOTION FOR CONTINUANCE OF SENTENCING Defendant, Charles Warren, by and through his undersigned counsel, Eleni Kousoulis, hereby moves the Court for an Order continuing the sentencing hearing in this case. In support of the motion, the defendant avers as follows: 1. 2. Mr. Warren is currently scheduled for sentencing on October 7, 2008 at 1:00 p.m. Mr. Warren's attorney, Eleni Kousoulis, will be out of the office on October 6, 2008

and October 7, 2008, and therefore unavailable on the date that Mr. Warren's sentencing is currently scheduled. The defense respectfully requests that the sentencing hearing in this matter be continued. 3. Assistant United States Attorney, Shawn Martyniak, the attorney handling this case

for the government, has no objection to the defendant's request for a continuance of the sentencing hearing in this case, making this motion unopposed.

Case 1:07-cr-00143-JJF

Document 34

Filed 08/12/2008

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WHEREFORE, Mr. Warren respectfully requests that the Court continue the sentencing hearing in this matter. Respectfully submitted,

/s/ Eleni Kousoulis Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 Attorney for Defendant Charles Warren

DATED: August 12, 2008

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Case 1:07-cr-00143-JJF

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Filed 08/12/2008

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLES WARREN, Defendant.

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Criminal Action No. 07-143-JJF

ORDER In response to Defendant Warren's Motion for Continuance of Sentencing, this Court HEREBY ORDERS on this ________ day of ____________________, 2008, that Defendant Warren's sentencing hearing be re-scheduled for the _______ day of _________________, 2008 at ________ a.m./p.m.

The Honorable Joseph J. Farnan, Jr. United States District Court