Free Motion to Continue - District Court of California - California

Case 3:08-cr-00626-JLS

Document 16

Filed 06/10/2008

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KAREN P. HEWITT United States Attorney CHRISTOPHER P. TENORIO Assistant U.S. Attorney California State Bar No. 166022 880 Front Street, Suite 6293 San Diego, California 92101-8893 Telephone: (619) 557-7843 [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. TOMAS RAMIREZ-PEREZ, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. DATE: TIME: 08CR0626-JLS

June 13, 2008 1:30 p.m.

JOINT MOTION TO CONTINUE SENTENCING HEARING

COMES NOW the plaintiff, UNITED STATES OF AMERICA, by and through its counsel, Karen P. Hewitt, United States Attorney, and Christopher P. Tenorio, Assistant United States Attorney, and Defendant, Tomas Ramirez-Perez, through his counsel, John C. Lemon, hereby move this court to continue the motion hearing currently scheduled from June 13, 2008 at 1:30 p.m. to July 25, 2008 at 1:30 p.m. for disposition. Defendant's counsel will be unavailable until that date due to scheduling conflicts. 25, 2008 is excluded. Dated: June 10, 2008 The parties stipulate that the time until July

s/ John C. Lemon

JOHN C. LEMON Attorney for Defendant KAREN P. HEWITT United States Attorney CHRISTOPHER P. TENORIO Assistant U.S. Attorney

s/Christopher P. Tenorio

Case 3:08-cr-00626-JLS

Document 16

Filed 06/10/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 08CR0626-JLS IT IS HEREBY CERTIFIED that: I, CHRISTOPHER P. TENORIO, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front v. TOMAS RAMIREZ-PEREZ, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR0626-JLS

CERTIFICATE OF SERVICE

Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. service of JOINT MOTION TO CONTINUE SENTENCING I have caused HEARING on the

following party by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them: John C. Lemon, Esq. I declare under penalty of perjury that the foregoing is true and correct. Executed on June 10, 2008 Respectfully submitted, KAREN P. HEWITT United States Attorney CHRISTOPHER P. TENORIO Assistant U.S. Attorney

s/Christopher P. Tenorio