Free Letter - District Court of Delaware - Delaware

Case 1:07-cr-00103-JJF

Document 19

Filed 12/21/2007

Page 1 of 2

FEDERAL PUBLIC DEFENDER DISTRICT OF DELAWARE
704 King Street, Suite 110 Wilmington, Delaware 19801
Phone (302) 573-6010 FAX (302) 573-6041 www.fpdde.org

Edson A. Bostic
Federal Public Defender

Eleni Kousoulis Luis A. Ortiz Keir Bradford Assistant Federal Public Defenders Tieffa N. Harper Research & Writing Specialist

December 21, 2007

The Honorable Joseph J. Farnan, Jr. United States District Court J. Caleb Boggs Federal Building 844 King Street Wilmington, DE 19801

Re:

United States v. Stanley Lum Criminal Action No.: 07-103-JJF Our File No.: 2007-00214

Dear Judge Farnan: This letter is written to supplement the Defense's oral request of December 17, 2007 to postpone the Suppression Hearing and to allow the filing of a supplemental motion to suppress, in the above-captioned matter. At that time, this Court granted the oral request and directed Counsel to confer with the government regarding the filing of a supplemental motion. In consulting upon this issue, the parties have determined that there is the possibility that this matter could be resolved by way of a non-trial disposition. To allow the parties additional time to complete these discussions regarding a non-trial disposition, Counsel is requesting that this Court permit thirty days from the date of this letter, for the filing of the supplemental motion. (If the parties reach an agreement on a non-trial disposition, the Court will be informed within that thirty day period.) Additionally, it is requested that the government be permitted ten days from the filing of any supplemental motion to respond.

Case 1:07-cr-00103-JJF

Document 19

Filed 12/21/2007

Page 2 of 2

Finally, assuming that a supplemental motion and response are filed, the parties would then ask this Court to schedule a hearing on the supplemental motion within thirty days of the government's response, if to do so would be convenient to the Court's calendar. Respectfully submitted,

___/s/______________ EDSON A. BOSTIC Federal Public Defender EAB/lmo cc: Shawn Weede, Assistant United States Attorney Stanley Lum, Defendant