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

Case 3:08-cr-00077-BTM

Document 23

Filed 02/26/2008

Page 1 of 1

1 WENDY S. GERBOTH California Bar No. 167687 2 964 Fifth Avenue, Suite 214 San Diego, California 92101 3 Telephone: (619) 699-5969 4 [email protected] 5 Attorney for Ms. Cuenca 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE BARRY T. MOSKOWITZ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0077-BTM Date: February 29, 2008 Time: 10:00 a.m. MOTION FOR ORDER TO SHORTEN TIME

11 UNITED STATES OF AMERICA, 12 13 v. 14 LAURA CUENCA-SERRANO, 15 16 17 Defendant. Plaintiff,

The above-named defendant, by and through counsel, moves this

18 Court for an order shortening time to file her Sentencing Memorandum to 19 three (3) days, to be heard February 29, 2008, at 10:00 a.m., or as soon 20 thereafter as counsel may be heard, for the following reasons: 21 When preparing Ms. Cuenca's sentencing papers last Friday

22 defense counsel realized she needed to meet with Ms. Cuenca with an 23 interpreter to clarify several issues, then needed to contact her parents 24 in Mexicali (through a third party, because they do not have a telephone) 25 to answer questions. 26 27 28 DATED: February 26, 2008 Respectfully submitted, /s/ Wendy S. Gerboth WENDY S. GERBOTH Attorney for Ms. Cuenca