Free Motion to Continue - District Court of California - California

Case 3:08-cr-00753-JLS

Document 25

Filed 07/08/2008

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Christian De Olivas CalBarNo. 249608 De Olivas Law Firm, APLC 200 N Bradford Ave, Ste L Placentia, CA 92870 Telephone: (714) 646-3314 Facsimile: (714) 646-3721 Email: [email protected] UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JUDGE JANICE L. SAMMARTINO) CASE: 3:08-cr-753-JLS-1 DATE: AUGUST 15, 2008 TIME: 9:00 AM NOTICE OF JOINT MOTION; JOINT MOTION TO CONTINUE SENTENCE WITH PROBATION OFFICE REPORT

UNITED STATES OF AMERICA, Plaintiff, vs. GUILLERMO ARANDA, Defendant

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NOTICE OF JOINT MOTION TO: THE UNITED STATES ATTORNEY; DEFENDANT PLEASE TAKE NOTICE that on the above-referenced date, Defendant, GUILLERMO ARANDA, by and through his counsel, CHRISTIAN DE OLIVAS, and the Plaintiff, the United States of America, by and through and its counsel, CHARLOTTE E. KAISER, will move this Court to grant the above-entitled motion. JOINT MOTION The Defendant, GUILLERMO ARANDA, by and through his counsel, CHRISTIAN DE OLIVAS, and the Plaintiff, the United States of America, by and through and its counsel, CHARLOTTE E. KAISER, and pursuant to Federal Rules

Joint Motion to Continue Sentence With Probation Office Report Hearing - 1

3:08-cr-753-JLS-1

Case 3:08-cr-00753-JLS

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of Criminal Procedure Evidence 7(f), 12, 14, and 16, and the Fourth, Fifth and Sixth Amendments to the United States Constitution, hereby move this Court to grant the above-stated motion. We all agree that the period of time reflected in this continuance is excludable pursuant to 18 USCA §3161(h)(8) from the time period within which the Sentence With Probation Office Report must commence as set forth in 18 USCA §3161(c)(1). In support thereof, Defense Counsel, and pursuant to and without objection by the Plaintiff s Counsel, request that the current Sentence with Probation Officer Report hearing date of JULY 11, 2008 at 9:00 and be continued to AUGUST 15, 2008, at 9:00 am, in order to prepare for said Sentencing hearing and Probation Office to prepare Presentencing Report.

Respectfully Submitted, DATED: July 8, 2008 SIGNED: /s/ Christian De Olivas CHRISTIAN DE OLIVAS ATTORNEY FOR DEFENDANT GUILLERMO ARANDA DATED: July 8, 2008 SIGNED: /s/ Charlotte E. Kaiser CHARLOTTE E. KAISER ATTORNEY FOR PLAINTIFF UNITED STATES OF AMERICA

Joint Motion to Continue Sentence With Probation Office Report Hearing - 2

3:08-cr-753-JLS-1

Case 3:08-cr-00753-JLS

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Filed 07/08/2008

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CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED THAT: 1. I, CHRISTIAN DE OLIVAS, am a citizen of the United States and am at least eighteen years of age. My business address is 200 N. Bradford Ave., Ste L, Placentia, California 92870. 2. I am not a party to the above-entitled action. I have caused service of the following documents: Notice of Joint Motion; Joint Motion to Continue Sentence With Probation Office Report Hearing on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them: a. Ms. Charlotte E. Kaiser, Assistant United States Attorney 3. I declare under penalty of perjury that the foregoing is true and correct. Executed on July 8, 2008.

DATED: July 8, 2008

SIGNED: /s/ Christian De Olivas CHRISTIAN DE OLIVAS ATTORNEY FOR DEFENDANT GUILLERMO ARANDA

Joint Motion to Continue Sentence With Probation Office Report Hearing - 3

3:08-cr-753-JLS-1