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

Case 3:08-cr-00063-LAB

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Filed 02/01/2008

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KAREN P. HEWITT United States Attorney DAVID L. KATZ Assistant United States Attorney California State Bar No. 141295 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-5226 / Fax: (619) 235-2757 Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. PEDRO GARCIA, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR0063-LAB MOTION TO SHORTEN TIME

The Government requests an order shortening time to February 1, 2008, to file its response and opposition to defendant's motions to: (1) compel discovery; (2) suppression of statements; and (3) grant leave to file further motions. This application is made for the following reasons: 1. Undersigned Government counsel has been in two (2) back-to-back trials since the

aforementioned defendant's motions were efiled. 2. Further, a third case was just set for trial for February 12, 2008, in the case of

U.S. v. Carlos Oliva-Reyes, Case No. 07cr1907-W, in which had to be prepared to go forward. 3. Undersigned Government counsel had to prepare motion responses in several other

cases and due to a viral infection, had to be out of the office a couple of times during the last two weeks. //

Case 3:08-cr-00063-LAB

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Filed 02/01/2008

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As a result, the undersigned Government counsel was unable to file this response and opposition in a timely fashion. DATED: February 1, 2008. Respectfully submitted, KAREN P. HEWITT United States Attorney s/David L. Katz DAVID L. KATZ Assistant United States Attorney Email: [email protected]

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Case 3:08-cr-00063-LAB

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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 IT IS HEREBY CERTIFIED THAT: I, DAVID L. KATZ, 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. I am not a party to the above-entitled action. I have caused service of MOTION TO SHORTEN TIME on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. 1. Carey D. Gorden, Esq. v. PEDRO GARCIA, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff CERTIFICATE OF SERVICE Case No. 08CR0063-LAB

I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case: N/A the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 1, 2008. s/David L. Katz DAVID L. KATZ Assistant United States Attorney