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

Case 3:08-cr-02125-WQH

Document 29

Filed 07/21/2008

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HOLLY S. HANOVER, Esq. California State Bar Number 177303 1016 La Mesa Ave. Spring Valley, CA 91977 Telephone: (619) 295-1264 E-Mail: [email protected] Attorney for Defendant, Jose Martinez Gonzalez UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (THE HON. WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARTINEZ GONZALEZ (2), Defendant. TO: ) ) ) ) ) ) ) ) CASE NO. 08cr2125-WQH DATE: August 4, 2008 TIME: 2:00 p.m. MOTION TO SHORTEN TIME

KAREN P. HEWETT, or current UNITED STATES ATTORNEY, AND JOSEPH J.M. ORABONA, or current ASSISTANT UNITED STATES ATTORNEY: Defendant, Jose Martinez Gonzalez, by and through his attorney,

Holly S. Hanover, moves this Court for an order to Shorten time for the filing of the Motions for Discovery, Suppression, and Joinder in CoCounsel's motions, with leave to file additional motions, to fourteen (14) days, for numerous reasons (counsel was ill during the normal preparation time for these motions, negotiations and discussions about resolving the matter without going to trial were actively on-going during the past week to try and avoid the filing of motions altogether, and because counsel was in the El Centro Rotation last week). Counsel

will submit a proposed order in word-perfect format by e-mail to the Court. Respectfully submitted, Dated: July 21, 2008 s/ Holly S. Hanover Attorney for Jose Martinez Gonzalez E-mail: [email protected]

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08cr2125

Case 3:08-cr-02125-WQH

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Filed 07/21/2008

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HOLLY S. HANOVER, Esq. California State Bar Number 177303 1016 La Mesa Ave. Spring Valley, CA 91977 Telephone: (619) 295-1264 E-Mail: [email protected] Attorney for Defendant, Jose Martinez Gonzalez UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (THE HON. WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARTINEZ GONZALEZ (2), Defendant. IT IS HEREBY CERTIFIED THAT: I, Holly Hanover, am a citizen of the United States and am at least 18 years of age. Spring Valley, CA, 91977 I have cause the service of the Motion to Shorten Time in this case. The following recipients are currently on the list to My business address is 1016 La Mesa Ave., ) ) ) ) ) ) ) ) CASE NO. 08cr2125-WQH DATE: August 4, 2008 TIME: 2:00 p.m. CERTIFICATE OF SERVICE

receive e-mail notices for this case and have thus been served electronically at the following e-mail addresses: // // // // // // // // 1 08cr2125

Case 3:08-cr-02125-WQH

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Name: Tamara DeHaan Erick Guzman

E-mail Address: [email protected] [email protected], [email protected]

Joseph J.M. Orobona

[email protected], [email protected], [email protected]

Respectfully submitted, 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08cr2125 Dated: July 21, 2008 s/

Holly Hanover

Attorney for Mr. Martinez-Gonzalez E-mail: [email protected]