UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
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v. : Criminal No.xx-0453 (JR)
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xxxxxxxxxxxxxxxxxx, :
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Defendant. :
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MOTION FOR CONTINUANCE OF MOTIONS HEARING
INCORPORATED MEMORANDUM OF SUPPORTING POINTS AND AUTHORITIES
xxxxxxxxxxx, through undersigned counsel, respectfully requests that this Honorable Court continue his motions hearing date scheduled for January 23, 1998, until February 13, 1998.
As grounds for his request, Mr. xxxxxxxxx, through undersigned counsel states:
1. Mr. xxxxxx is currently scheduled for a motions hearing on January 23, 1998. Undersigned counsel was advised on Friday, January 16, 1998, that a motions hearing was scheduled for January 20, 1998, the following Wednesday. The January 20th date was rescheduled until January 23, 1998. Undersigned counsel was advised to file a written motion if counsel required additional time to prepare for the motions hearing.
2. Mr. xxxxxx stands charged by indictment with one count of possession with intent to distribute cocaine, in violation of 21 U.S. Code §§ 841(a)(1) and 841(b)(1)(C), and unlawful possession of a firearm and ammunition, in violation of 18 U.S. Code § 922(g)(1).
3. Due to previously scheduled deadlines and assignments, undersigned counsel requires additional time to prepare for Mr. xxxxxx's motions hearing.
4. In addition, a reassignment of cases resulting from the departure of two attorneys from the Office of the Federal Public Defender, have required undersigned counsel to reschedule and reprioritize an increased caseload.
WHEREFORE, for all the foregoing reasons, and for any other reasons this Court may deem just and proper, Anthony xxxxxx, through undersigned counsel, respectfully requests that this Court grant him a continuation, and schedule his motions hearing for February 13, 1998.
Respectfully submitted,
A. J. Kramer
Federal Public Defender
Valencia Rainey
Assistant Federal Public Defender
625 Indiana Avenue, N.W., Suite 550
Washington, D.C. 20004
202-208-7500
CERTIFICATE OF SERVICE
I hereby certify that on the 13th day of January 1998, the Defendant's Motion For A Continuance of Motions Hearing was sent via facsimile to Umi Choi, Esq., Assistant United States Attorney, Office of the United States Attorney, 555 -4th St., N.W., Washington, D.C. 20001, facsimile (202)307-2304.
Valencia Rainey
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
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v. : Criminal No. xx-0453 (JR)
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ANTHONY xxxxxx, :
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Defendant. :
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ORDER
Upon consideration of Defendant Anthony xxxxxx's Motion for Continuance of Motions Hearing and Incorporated Memorandum of Supporting Points and Authorities, it is this ____ day of January, 1998, hereby
ORDERED that the Motion is granted; and it is further
ORDERED that the motions hearing date is continued until ______________1998.
_____________________________
JAMES ROBERTSON UNITED STATES DISTRICT JUDGE
Copies To:
Valencia Rainey, Esq.
Assistant Federal Public Defender
625 Indiana Ave., N.W. Suite 550
Washington, DC 20004
(202)208-7500
Umi Choi, Esq.
Assistant United States Attorney
Office of the United States Attorney
555 Fourth St., N.W.
Washington, D.C. 20001
(202)305-0634