Free Motion to Continue - District Court of Delaware - Delaware

Case 1 :07-cr-00101-GIVIS Document 12 Filed 09/18/2007 Page 1 of 1
Jerome M. Capone
Attomey-At-Law
1823 west 16"‘ street Ph<>¤<= (302) 664-3260
Wilmington, Delaware 19806 Fax (302) 6544281
_ ..— [email protected]
at the comer of 16'*‘ & Lincoln Sts. WWW·l€nyCapOn€·COm
September 18, 2007
The Honorable Gregory M. Sleet
United States District Court
844 North King Street
Lock Box 19
Wilmington, DE 19801
Re: United States v. Michael Pingatore! Case N0. 07-101 GMS
Dear Judge Sleet:
On July 23, 2007, Defendant Michael Pingatore entered a plea in the above
captioned case. Currently his sentencing date is set for October 22, 2007 at 2:00 p.m.
I am writing to request a continuance for the following reason.
During this time of presentence preparation, Mr. Pingatore has been seen by Dr.
Pedro Ferreira, a psychologist. The expectation had been that Dr. Ferreira would submit a
report as to his findings to me, Robert Kravitz, Esq. and Marty Durkin, the presentence
officer by September 17, 2007. It has come to my attention that Dr. Ferreira will be
unable to meet that deadline. Therefore I feel it is necessary to request a continuance of
the sentencing date in order provide all parties ample time to review the report. In
addition, I am requesting that the sentencing be rescheduled for sometime after
November 10, 2007 because Mr. Pingatore’s son will be getting married that day. I have
contacted the prosecutor, Robert Kravitz, Esq., and he would like to contact the victim in
this matter before stating his position on this request.
If I can provide any further information to the Court, please contact me.
Res ct l ` d,
¤1a·{ .
JMC/kb
cc: Robert Kravitz, Esq. F I L E D
Martin Durkin
SEP 1 8 2007
u.s. msrmcr count
1 oisrmcr OF DELAWARE