Free Motion to Continue - District Court of Delaware - Delaware

Case 1:07-cr-00123-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. TARIREEF WHITE, Defendant.

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Criminal Action No. 07-123-SLR

MOTION FOR CONTINUANCE OF TELEPHONE STATUS CONFERENCE The defendant, Tarireef White, through undersigned counsel Eleni Kousoulis, hereby moves this Honorable Court for an Order continuing the telephone status conference in this case. In support of this motion, the defense submits as follows: 1. A telephone status conference in this matter is currently scheduled for November 9,

2007 at 9:00 a.m. 2. Defense counsel will be out of the office from November 7, 2007, through November

15, 2007. Therefore, defense counsel will be unavailable on November 9, 2007, the date that Mr. White's telephone status conference is currently scheduled. Additionally, defense counsel needs additional time to meet with Mr. White to determine how the defense will be proceeding in this case. 3. be continued. 4. Assistant United States Attorney, Martin Meltzer, the attorney handling this case for Defense counsel respectfully requests that Mr. White's telephone status conference

the government, has no objection to the defense's continuance request.

Case 1:07-cr-00123-SLR

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Filed 11/01/2007

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5.

The defense agrees to waive the time from November 9, 2007, until the date of

the continuance for purposes of the Speedy Trial Act (18 U.S.C. § 3161, et seq.). 6. Defense counsel was informed by the Court's chambers that the Court is

available on November 29, 2007 at 9:00 a.m. to hold the telephone status conference in this case. All parties are available at that time. WHEREFORE, for these reasons and any other such reasons that shall appear to the Court, the defense respectfully requests a continuance of the telephone status conference in this case to November 29, 2007 at 9:00 a.m. Respectfully submitted,

/s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, DE 19801 (302) 573-6010 [email protected] Counsel for Defendant Tarireef White

Dated: November 1, 2007

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Case 1:07-cr-00123-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. TARIREEF WHITE, Defendant. : : : : : : : : :

Criminal Action No. 07-123-SLR

ORDER The Court having considered the Defendant's Motion for Continuance of Telephone Status Conference, good cause having been shown therefore; IT IS HEREBY ORDERED this day of , 2007 that

the defendant's motion is hereby granted, and the telephone status conference in this case is rescheduled for the _______ day of _______________ , 2007, and that the time from November 9, 2007 up to the date of the scheduling conference shall be excluded under the Speedy Trial Act (18 U.S.C. § 3161, et seq.).

HONORABLE SUE L. ROBINSON United States District Court