Free Response to Motion - District Court of Delaware - Delaware

I Case 1:07-cr-00106-JJF Document 35 Filed 12/12/2007 Page 1 of 3
` IN THE UNITED STATES DISTRICT COURT -
. ‘ I FOR THE DISTRICT OF DELAWARE _
UNITED STATES OF AMERICA, : n
Piaiutirr, 5
l - v. Criminal Case N0. 07-106 JJF
DAYWON DRUMMOND, I I I
Defendant. . L
` i I RESPONSE TO DEFENDANT’S MOTION FOR CONTINUAN CE `
l The United States ofAn1e1ica, by its attorneys, Colm F. Connolly, United States Attorney _
for the District of Delaware, and Martin C. Meltzer, Special Assistant United States Attorney, {
I respectfully request this Honorable Court to grant the defendant’s Motion for a Continuance for
thirty days excluding the thirty days pursuant to 18 U.S.C. § 3 1 6l(h)(1)(F) & (H). In support of this
motion, the parties aver as follows:
K l. An evidentiary hearing is scheduled for December 10, 2007 and the defense has
requested a continuance with no objection by the government. q
I 2. The parties believe this matter will resolve itself prior to trial and the additional time I
is needed to resolve the details. i
· n 3. The defendant is not incarcerated and resides with his family.
· _ 4. The defendant explicitly waives any and all rights involving a speedy trial based
‘ upon this requested continuance. I _

_ Case 1 :07-cr-00106-JJF Document 35 Filed 12/12/2007 Page 2 of 3
` WHEREFORE, it is respectfully requests that the Court grant a continuance in this
matter and that any period of continuance is excluded in computing the time within which the
trial must commence, pursuant to 18 U.S.C.§ 3l6l(h)(l)(F)&(H). A proposed Order is attached.
i Respectfully submitted,
COLM F. CONNOLLY .
- p _,,United States Attorn
.*'" _ _ /
' _ fl F l
_ ` Martin C. Meltzer 1 i
Special Assistant United States { ttomey f
-2- i i i U

_ Case 1 :07-cr-00106-JJF Document 35 Filed 12/12/2007 Page 3 of 3 I
n in IN THE UNITED STATES DISTRICT COURT
I _ FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, : I
. . Plaintiff,
n - v. Criminal Case N0. 07-106 JJF U U
DAYWON DRUMMOND, I _
‘ Defendant. -
I n O R D E R
And now, this___day of December 2007, the Court finds that, for the reasons
stated in the above MOTION FOR CONTINUANCE AND EXCLUSION OF TIME UNDER
THE SPEEDY TRIAL ACT, the ends of justice to be served by granting a continuance in this
matter, pursuant to Title 18, United States Code, Section 3161(h)(1)(F)&(H),
. · IT IS HEREBY ORDERED that a continuance Hom December 14, 2007 through
, is granted in this case, and that this period ofthe continuance will be
. . excluded in computing the time within which the trial must commence.
t I
United States District Court .