Free Motion to Continue - District Court of California - California

Case 3:08-cr-02712-LAB

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Patrick J. Hennessey Jr. Attorney At Law (047993) 2356 Moore Street, Suite 201 San Diego, CA 92110 (619) 298-7802

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. LARRY ALAN BURNS, JUDGE) UNITED STATES OF AMERICA, Plaintiff, v. MIREYA ENRIQUEZ VELASQUEZ, Defendant. CASE NO. 08CR2712(2) LAB DECLARATION OF UNAVAILABILITY AND REQUEST FOR CONTINUANCE OF MOTION DATE

I, Patrick J. Hennessey, Jr., declare: I have been retained by Mireya Enriquez Velasquez to represent her in the above case. At the time counsel was

retained, a motion date had been set for September 22, 2008, at 2:00 p.m. before the Honorable Larry A. Burns. I will be out of I have

the country between September 3 and September 23, 2008.

spoken with Lela Morgan of Federal Defenders Inc. who represents the codefendant and indicated I would not be available to appear on that date. Counsel would also note that assistant United

i ______________________________________ VELASQUEZ.DEC

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States Attorney, Christopher Tenorio, is on leave and will not return to the office until September 2 or 3, 2008. As a result, counsel would request the court continue the motion hearing until either September 29, or October 6, 2008. I declare under penalty of perjury the foregoing is true and correct. Dated at San Diego, California, this 1st day of

September, 2008.

Dated:9/1/08

/S/Patrick Hennessey _____ PATRICK J. HENNESSEY, JR. Attorney for Defendant

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i ______________________________________ VELASQUEZ.DEC

CERTIFICATE OF MAIL

I, the undersigned, declare that: I am over the age of eighteen years and not a party to the action; I am employed in the County of San Diego, California, within which county the subject mailing occurred; my business address is 2356 Moore Street, Suite 201, San Diego, California; I am familiar with this firm's practice for collection and processing correspondence for mailing with the United States Postal Service pursuant to which practice all correspondence will be deposited with the United States Postal Service the same day in the ordinary course of business. I served the following document(s):

DECLARATION OF UNAVAILABILITY AND REQUEST FOR CONTINUANCE OF MOTION DATE
by placing a copy thereof for each addressee named hereafter, addressed to each such addressee, in a separate envelope, postage prepaid, sealed and deposited at this firm's mailstation on 9/1/08 . Office of the United States Attorney 880 Front Street, Room 6293 San Diego, CA 92101 Federal Defenders, Inc. 225 Broadway, Suite 900 San Diego, CA 92101

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on 9/1/08.

/S/_Patrick Hennessey____________________________ PATRICK J. HENNESSEY, JR.

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