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

Case 3:08-cr-00783-DMS

Document 18

Filed 05/14/2008

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KAREN P. HEWITT United States Attorney REBECCA S. KANTER Assistant U.S. Attorney California State Bar No. 230257 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone No: (619) 557-6747 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. RICARDO AVALOS-RAMIREZ, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08cr0783-DMS APPLICATION FOR ORDER SHORTENING TIME

COMES NOW, the plaintiff, UNITED STATE OF AMERICA, by and through its counsel, Karen P. Hewitt, United States Attorney, and Rebecca S. Kanter, Assistant United States Attorney, and hereby moves this court for an order shortening time to allow the filing of the Government's Response and Opposition to Defendant's Motion for Discovery. This application is made for the following reasons: (1) (2) (3) This case was originally assigned to Assistant United States Attorney Jeffrey Moore. When Defendant filed his Motion to Compel Discovery, AUSA Moore was on vacation and out of the office; he therefore did not receive or respond to the motion. This case and the related case, 08cr1361-DMS, was reassigned to the undersigned on May 13, 2008, as evidenced by the Notice of Appearance filed in the related case. Respectfully submitted, KAREN P. HEWITT United States Attorney Dated: May 14, 2008. s/ Rebecca Kanter REBECCA S. KANTER Assistant U.S. Attorney

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Case 3:08-cr-00783-DMS

Document 18

Filed 05/14/2008

Page 2 of 2

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 SOUTHERN DISTRICT OF CALIFORNIA 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS HEREBY CERTIFIED THAT: I, REBECCA S. KANTER, 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 GOVERNMENT'S MOTION TO SHORTEN 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. Mark Chambers 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 May 14, 2008. /s/ Rebecca Kanter REBECCA S. KANTER UNITED STATES OF AMERICA, ) Criminal Case No. 08cr0783-DMS ) Plaintiff, ) ) CERTIFICATE OF SERVICE v. ) ) RICARDO AVALOS-RAMIREZ, ) ) Defendant. ) )