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

Case 3:08-cr-00019-LAB

Document 6-2

Filed 01/15/2008

Page 1 of 1

JODI D. THORP California State Bar No. 223663 2 Law Offices of Jodi Thorp 427 C. Street, Suite #300 3 San Diego, California 92101 Telephone: (619) 233-3169, x.16
1 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

Attorneys for Mr. Barajas-Cruz

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE LARRY A. BURNS) UNITED STATES OF AMERICA, Plaintiff, v. SALVADOR BARAJAS-CRUZ Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0019-LAB

DECLARATION OF COUNSEL IN SUPPORT OF MOTION TO SHORTEN TIME

I, Jodi D. Thorp, hereby declare as follows: 1. 2. 3. 4. 5. 6. 7. I was appointed to represent Mr. Barajas in the above-captioned case. In late December 2007 and early January 2008, I was ill for approximately two weeks. At that time, Mr. Barajas' case had not yet been indicted. Mr. Barajas' case was subsequently indicted on January 2, 2008. He was arraigned on the indictment on January 4, 2008. The magistrate judge set the motion hearing less than three weeks from the date of the arraignment on the indictment due to this being part of a related case with a previously scheduled motion hearing date. I needed time to file motions in this case. I swear that, to the best of my knowledge and memory, the foregoing is true and correct. Dated: January 15, 2008 s/ Jodi Thorp Jodi Thorp