Free Motion to Continue - District Court of California - California

Case 3:08-cr-01457-L

Document 24

Filed 06/05/2008

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1 MICHAEL LITTMAN CA State Bar # 120625 2 105 West "F" St., 4 th Flr. San Diego, CA 92101 3 (619) 236-1030 4 Attorney for Defendant BRUNO DE JESUS LOPEZ-PEDROZA 5 6 7 8 9 10 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 OSCAR MOISES RAMIREZ, et al. 15 Defendants. 16 17 ) ) ) ) ) ) ) ) ) ) Case No. 08-CR-1457-L JOINT MOTION TO CONTINUE MOTION HEARING UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Hon. M. James Lorenz)

THE PARTIES HEREBY STIPULATE AND JOINTLY MOVE THE COURT,

18 by and between the parties, Carlos Arguello, counsel for the United States; Joseph 19 McMullen, counsel for defendant OSCAR MOISES RAMIREZ; Russell Babcock, counsel 20 for CLAUDIA CALDERON-MORALES; and Michael Littman, counsel for defendant 21 BRUNO DE JESUS LOPEZ-PEDROZA, for an order vacating the currently scheduled 22 motion hearing of June 9, 2008, and continuing it to June 23, 2008 at 2:00 p.m. The parties 23 believe it would be in the interest of justice to continue the motion hearing in this matter in 24 order to further discuss this matter which may result in a resolution of the case without 25 trial. 26 27 1. 28 Therefore, the parties jointly request and agree as follows: The motion hearing for all defendants shall be continued from June 9, 2008 at 2:00 p.m. to June 23, 2008 at 2:00 p.m.

Case 3:08-cr-01457-L

Document 24

Filed 06/05/2008

Page 2 of 2

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The time is excludable pursuant to the Speedy Trial Act. Claudia Calderon-Morales and Bruno De Jesus Lopez-Pedroza are in custody and Oscar Moises Ramirez is out of custody on bond. All defendants consent to the continuance. So stipulated and moved.

7 DATED: June 5, 2008 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

s/ Michael Littman Attorney for Defendant STEVE ROMEO s/ Joseph McMullen Attorney for Defendant OSCAR MOISES RAMIREZ s/ Russell Babcock Attorney for Defendant CLAUDIA CALDERON-MORALES Karen P. Hewitt United States Attorney s/ Carlos Arguello Assistant U.S.Attorney Attorney for Plaintiff

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