Free Motion to Continue - District Court of California - California

Case 3:08-cr-00760-JLS

Document 18

Filed 06/17/2008

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KAREN P. HEWITT United States Attorney LARA A. STINGLEY Assistant U.S. Attorney California State Bar No. Pending United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-6244 / (619) 557-5551(Fax) Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. MICHELE MCKNIGHT, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR0760-JLS DATE: June 20, 2008 TIME: 9:00 a.m. JOINT MOTION TO CONTINUE SENTENCING

NOW COMES plaintiff United States of America, by and through its counsel, United States Attorney Karen P. Hewitt and Assistant U.S. Attorney Lara A. Stingley, and defendant Michele McKnight, by and through her counsel Michelle Betancourt, and herein jointly request this Court to continue the sentencing hearing currently set for June 20, 2008, at 9:00 a.m to August 8, 2008, at 9:00 a.m. The basis for this request is that the defense and the prosecution are involved in postplea negotiations. DATED: June 17, 2008. Respectfully submitted, Karen P. Hewitt United States Attorney s/Lara A. Stingley___________ Lara A. Stingley Assistant United States Attorney Attorneys for Plaintiff United States of America s/ Michelle Betancourt Michelle Betancourt, Esq. [email protected] Attorney for Defendant Michele McKnight

Case 3:08-cr-00760-JLS

Document 18

Filed 06/17/2008

Page 2 of 2

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

3 4 UNITED STATES OF AMERICA, 5 Plaintiff, 6 v. 7 MICHELE MCKNIGHT 8 Defendant. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Michelle Betancourt, Esq. [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on June 17, 2008. s/ Lara A. Stingley Lara A. Stingley I am not a party to the above-entitled action. I have caused service of the Joint Motion to Continue Sentencing 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, Lara A. Stingley, 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. 08CR0760-JLS

CERTIFICATE OF SERVICE