Free Motion to Shorten Time - District Court of California - California

Case 3:08-cr-02124-IEG

Document 11

Filed 08/11/2008

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KAREN P. HEWITT United States Attorney DOUGLAS KEEHN Assistant U.S. Attorney California State Bar No. 233686 United States Attorney's Office Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-6549 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. JUAN DIEGO EMILIANO-LOYA, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR2124-IEG Date: August 15, 2008 Time: 9:00 a.m. Court: The Hon. Irma E. Gonzalez APPLICATION FOR ORDER SHORTENING TIME

NOW COMES plaintiff United States of America, by and through its counsel, U.S. Attorney Karen P. Hewitt and Assistant U.S. Attorney Douglas Keehn and hereby moves this Court for an order shortening time to (1) respond to Defendant's motions untimely filed, and (2) allow the filing of the Government's Motions for Reciprocal Discovery and Fingerprint Exemplars. Application is respectfully made for the following reasons: (1) (2) Defendant's trial is currently set for September 3, 2008 at 9:00 a.m. Defendant untimely filed his Motions to Compel Discovery, Preserve Evidence and Leave to File Further Motions on August 1, 2008. In advance of the Motion Hearing on August 4, 2008, counsel informed the United States that he would be seeking a continuance; at hearing, counsel requested a trial date.

(3)

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Case 3:08-cr-02124-IEG

Document 11

Filed 08/11/2008

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(4)

The undersigned has advised opposing counsel of this Application, and has provided counsel with the Proposed Order under separate cover, pursuant to Local Rules and Electronic Case Filing Policies and Procedures.

DATED: August 11, 2008 Respectfully submitted, KAREN P. HEWITT United States Attorney

/s/ Douglas Keehn DOUGLAS KEEHN Assistant United States Attorney

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Case 3:08-cr-02124-IEG

Document 11

Filed 08/11/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR2124-IEG CERTIFICATE OF SERVICE

JUAN DIEGO EMILIANO-LOYA, Defendant.

IT IS HEREBY CERTIFIED THAT: I, Douglas Keehn, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of APPLICATION FOR ORDER SHORTENING TIME on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. John Ellis, Esq. Federal Defenders of San Diego, Inc. [email protected]; [email protected] I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case: None the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 11, 2008. /s/ Douglas Keehn DOUGLAS KEEHN

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