Free Motion to Vacate - District Court of California - California

Case 3:07-cr-03450-JLS

Document 13

Filed 01/30/2008

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MICHAEL L. CROWLEY (117008) Attorney at Law 550 West "C" Street, Suite 1960 San Diego, CA 92101 (619) 444-8808 Attorney for Defendant

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Honorable Leo S. Papas)
) ) Plaintiff, ) ) v. ) ) ) MANUEL AGUIRRE-SEPULVEDA, ) ) Defendant. ) ________________________________) UNITED STATES OF AMERICA, Case Nos.: 07mj8956/07CR3450-JLS JOINT MOTION TO VACATE CHANGE OF PLEA HEARING

IT IS HEREBY JOINTLY MOVED by and between the parties to the above entitled case, MANUEL AGUIRRE-SEPULVEDA, by and through his counsel, MICHAEL L. CROWLEY, and the United States Attorney's Office, by and through Assistant United States Attorney, JEFF MOORE, that the Change of Plea Hearing scheduled for Thursday, January 31, 2008 at 9:30 a.m. before the Honorable Leo S. Papas be vacated due to the current lack of agreement being made and technical difficulties of the government regarding discovery. Defendant, MANUEL AGUIRRESEPULVEDA, is in custody. AUSA JEFF MOORE agrees and supports this continuance. A proposed order with respect to this joint motion is being submitted directly to the court.

DATED: January 30, 2008

/s/ Michael L. Crowley Michael L. Crowley, Esq. Attorney for Defendant /s/ Jeff Moore Jeff Moore Assistant U.S. Attorney Attorney for Plaintiff

DATED: January 30, 2008