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

Case 1:07-cr-00115-SLR

Document 13

Filed 09/27/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLES A. WEBSTER, JR., Defendant.

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Criminal Action No. 07-115-SLR

MOTION TO EXTEND TIME TO FILE PRE-TRIAL MOTIONS Defendant, Charles A. Webster, Jr., by and through his undersigned counsel, Luis A. Ortiz, hereby moves the Court pursuant to Federal Rule of Criminal Procedure 45(b) and Local Rule 5(a), for an Order enlarging the time within which pre-trial motions may be filed. In support of this motion, the Defendant submits as follows: 1. 2. Pre-trial motions for this case are due by September 28, 2007. Defense counsel has requested discovery and it is anticipated that partial discovery will

be received shortly. Defense counsel needs additional time to review and discuss the discovery with his client, to determine what, if any, pretrial motions need to be filed. There is also some investigation that the defense is conducting which is not yet complete, but which is needed prior to the filing of any motions. 3. AUSA Douglas McCann, the attorney handling this case for the government, does not

oppose the defense's request for an enlargement of time in which to file any pre-trial motions, making this motion unopposed. 4. Defense counsel, therefore, respectfully requests an additional 30 days in which to

Case 1:07-cr-00115-SLR

Document 13

Filed 09/27/2007

Page 2 of 2

file pre-trial motions, to allow sufficient time to complete any investigation in this case, review the discovery, and to discuss the case in general with Mr. Webster. 5. The defense agrees to waive, pursuant to the Speedy Trial Act, any additional time

given in which to file pre-trial motions. WHEREFORE, it is respectfully requested that the time for Defendant to file pre-trial motions be extended to anytime after October 29, 2007.

Respectfully Submitted,

/s/ Luis A Ortiz, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Charles A. Webster, Jr. Dated: September 26, 2007

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Case 1:07-cr-00115-SLR

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Filed 09/27/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. CHARLES A. WEBSTER, JR., Defendant.

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Criminal Action No. 07-115-SLR

ORDER Having considered Defendant Webster's Motion to Extend Time to File Pre-trial Motions, IT IS HEREBY ORDERED this day of day of , 2007, that Defendant , 2007.

Webster's pre-trial motions shall be due on the

Honorable Sue L. Robinson United States District Court