Free Motion to Continue - District Court of California - California

Case 3:08-cr-00750-JLS

Document 25-3

Filed 04/17/2008

Page 1 of 2

1 DAVID J. ZUGMAN California State Bar Number 190818 2 964 Fifth Avenue, Suite 300 San Diego, California 92101 3 Telephone: (619) 699-5931 Facsimile: (619) 699-5932 4 [email protected] 5 Attorney for Christopher Martin 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JANIS L. SAMMARTINO)

11 UNITED STATES OF AMERICA,

) Case No. 08CR0750-JLS ) 12 Plaintiff, ) ) 13 v. ) ) 14 CHRISTOPHER PAUL MARTIN, (2), ) DECLARATION IN SUPPORT OF MOTION ) TO CONTINUE THE SENTENCING HEARING 15 Defendant. ) ) 16 I, David J. Zugman, declare as follows. 17 1. I am the attorney assigned to represent Mr. Martin in the 18 above captioned case. 19 2. Mr. Martin's sentencing hearing is scheduled for June 23, 20 2008. 21 3. Due to Counsel's schedule, the interview with the Probation 22 Officer had to be put off until the week of April 28th. That only gives 23 the officer a few days to get the report written, approved, and filed. 24 4. A brief continuance of the sentencing hearing would allow the 25 Probation Officer sufficient time to file the report. 26 5. Counsel contacted this Court's clerk and explained the above. 27 The first available date for a rescheduled sentencing hearing is July

Case 3:08-cr-00750-JLS

Document 25-3

Filed 04/17/2008

Page 2 of 2

1 11, 2008. 2 6. Counsel has contacted the Probation Officer, Lisa DeLaney and

3 the Assistant U.S. Attorney, Carlos Cantu, both of whom do not object to 4 this request. 5 8. Mr. Martin asks that the Court reschedule his sentencing

6 hearing to July 11, 2008. 7 9. This request does not affect Mr. Martin's codefendant, Randy because Mr. Thompson has a different Probation Officer

8 Thompson,

9 assigned to his case and his Probation Interview has already been 10 completed. 11 FURTHER I DECLARE NOT: 12 Respectfully Submitted, 13 14 Dated: April 17, 2008 15 16 17 18 19 20 21 22 23 24 25 26 27 2 S/David Zugman DAVID ZUGMAN ATTORNEY FOR MR. MARTIN