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

Case 3:08-cr-02104-L

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Filed 07/18/2008

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KAREN P. HEWITT United States Attorney STEWART M. YOUNG Assistant U.S. Attorney California State Bar No. 234889 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-6228 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. JOSE LUIS SALDANA-RODRIGUEZ, ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08-CR-2104 L DATE: July 21, 2008 TIME: 2:00 p.m. MOTION FOR ORDER SHORTENING TIME

11 12 Defendant. 13 14

The United States moves this Court for an order shortening time to response to defendant's 15 motions to 1 (1) day, to be heard July 21, 2008 at 2:00 p.m, or as soon thereafter as counsel may 16 be heard, for the following reason: 17 1) Undersigned counsel has been in trial since July 15, 2008, in Case No. 07-CR-1430 JAH 18 (Donald Deshotels), which ended on July 17, 2008 in the afternoon. Undersigned counsel has been 19 preparing for trial in Case No. 08-CR-283 IEG which begins on July 22, 2008. Additionally, 20 undersigned counsel received the transcript of defendant's post-arrest interview, which was an 21 issue in defendant's motions, on the afternoon of July 17, 2008, and wanted to include it with the 22 motion response. Given these reasons, undersigned counsel has been unable to submit the response 23 to defendant's motions until today, July 18, 2008. 24 DATED: July 18, 2008 25 26 27 28 KAREN P. HEWITT United States Attorney s/Stewart M. Young___________ Stewart M. Young Assistant United States Attorney Respectfully submitted,

Case 3:08-cr-02104-L

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Filed 07/18/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

3 4 UNITED STATES OF AMERICA, 5 Plaintiff, 6 v. 7 JOSE LUIS SALDANA-RODRIGUEZ, 8 Defendant. 9 10 11 12 13 14 1. Robert Henssler, Esq. 15 I declare under penalty of perjury that the foregoing is true and correct. 16 Executed on July 18, 2008. 17 18 19 20 21 22 23 24 25 26 27 28 2 s/Stewart M. Young Stewart M. Young I am not a party to the above-entitled action. I have caused service of the Motion 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. IT IS HEREBY CERTIFIED THAT: I, Stewart M. Young, 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. ) ) ) ) ) ) ) ) ) ) Case No.08-CR-2104 L

CERTIFICATE OF SERVICE