Free Motion to Continue - District Court of Delaware - Delaware

I Case 1 :07-cr-00111-JJF Document 28 Filed O4/O3/2008 Page 1 of 3
I I IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, 3
vs. 3 Criminal Action No. 07-1 l 1-J JF
, KWAN MILLER, afk/a I
KENNETH MILLER )
Q ` Defendant. 3
_ JOINT MOTION TO CONTINUE HEARING
NOW COMES the defendant Kwan Miller, by and through his attorney, Assistant Federal
A Public Defender Keir Bradford, Esq., and the United States of Amenca, by and through its
attorney, Colm F. Connolly, United States Attorney, and Assistant United States Attorney Robert
F. Kravetz, and jointly requests the Court to continue the date of a hearing scheduled on the I
_ defendant’s Motion to Suppress Evidence. In support of this motion, the parties submit as I
C . follows: I
1. The defendant was indicted on August 17, 2007. The defendant filed a pre-trial
I Motion to Suppress Evidence dated March 7, 2008, and this Court scheduled a hearing on that I
I I motion for April 3, 2008 I
2. The parties have been discussing the possibility of resolving the defendant’s
pending federal charges. Since resolving the defendant’s pending federal charges would have _
collateral consequences on a pending violation of probation petition tiled against the defendant in
I I the Delaware Superior Court, the parties must involve the Delaware Attorney General’s Office II
and the defendant’s state counsel in those discussions. The United States Attorney’S Office has

Case 1 :07-cr-00111-JJF Document 28 Filed O4/O3/2008 Page 2 of 3
l been in contact with the Delaware Attorney Genera1’s Office in- an attempt to resolve this matter
i globally.
3. ln order to permit the parties to attempt to resolve the defendant’s pending charges
prior to trial, the parties request the Court to continue the det`endant’s hearing on his Motion to
0 Suppress Evidence until the week of April 21, 2008, or until such time as is convenient to the
Court’s schedule.- ‘ _
T 4. The parties request that the time between the date of this order and the date ofthe l
· _ hearing b_e excluded under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(8)(A).
` Respectfully submitted,
` /s/ Keir Bradford /s/ Robert F. Kravetz
Keir Bradford, Esq. ‘ Robert F. Kravetz, Esq.
Assistant Federal Public Defender Assistant United States Attorney
First Federal Plaza District of Delaware
704 King Street, Suite 110 Nemours Building ?
Wilmington, DE 19801 1007 Orange Street, Suite 700 _
_ Attorney for defendant Kwan Miller Wilmington, DE 19899 _
Dated: April 3, 2008
. K 2 r .

_ I Case 1 :07-cr-00111-JJF Document 28 I Filed O4/O3/2008 Page 3 of 3
i g IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
J UNITED STATES OF AMERICA, )
J Plaintiftl J
I vs. J Criminal Action No. 07-11 1-J J F _
l KWAN MILLER, a/k/a J J
I KENNETH MILLER ) ,.
A l Defendant. J
onninz
I Having considered the par|;ies’ Joint Motion to Continue Sentencing Act, IT IS HEREBY
J ORDERED this day of April 2008 that the motion is GRANTED. A hearing on the
. defendant’s Motion to Suppress Evidence shall commence on , 2008 at .
The time between the date ofthe Joint Motion and the date of thenhearing shall be excluded under
the Speedy Trial Act pursuant to 18 U.S.C. §§ 3 l6l(h)(8)(A).
_ U United States District Judge ,
3 l :_