Free Motion to Continue - District Court of California - California

Case 3:08-cr-00033-BEN

Document 16

Filed 04/09/2008

Page 1 of 1

1 HOLLY S. HANOVER, Esq. California State Bar Number 177303 2 1016 La Mesa Ave. Telephone: (619) 295-1264 3 E-Mail: [email protected] Attorney for Defendant Rodolfo Ozuna 4 5 6 7 8 UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) CASE NO. 07cr0033-BEN DATE: April 21, 2008 TIME: 9:00 a.m. JOINT MOTION TO CONTINUE THE PLEA ACCEPTANCE/SENTENCING DATE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. ROGER T. BENITEZ)

9 v. 10 RODOLFO OZUNA, Defendant. 11 12 TO: 13 14

KAREN P. HEWETT, or current UNITED STATES ATTORNEY, AND FRED SHEPPARD, or current ASSISTANT UNITED STATES ATTORNEY: Defendant, Rodolfo Ozuna, by and through his counsel, Holly S.

15 Hanover, and the government, jointly request that the Acceptance of 16 Plea/Sentencing date and time for Mr. Ozuna now set for April 21, 2008 17 at 9:00 a.m., be continued to June 2, 2008 at 9:00 a.m. The parties

18 also agree that the time between these dates should be excluded, as it 19 is important for both parties to work through some sentencing issues 20 before proceeding with sentencing. Mr. Ozuna is in custody. A proposed 21 order will be attached to the courtesy copy provided to the Court via 22 e-mail. 23 24 Dated: April 9, 2008 25 26 27 28 1 07cr0033 Respectfully submitted, s/ Holly S. Hanover Attorney for Benedicta Arreola s/ Fred Sheppard Assistant United States Attorney