Free Motion for Extension of Time to File - District Court of California - California

Case 3:07-cr-03472-WQH

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Filed 07/30/2008

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KAREN P. HEWITT United States Attorney DAVID L. KATZ Assistant U.S. 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 Email:[email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. RODOLFO GONZALEZ-RUIZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07cr3472-WQH GOVERNMENT'S REQUEST FOR EXTENSION OF TIME TO FILE ITS RESPONSE & OPPOSITION TO DEFENDANT'S MOTION TO DISMISS Date: August 18, 2008 Time: 2:00 p.m.

The plaintiff, UNITED STATES OF AMERICA, by its counsel, KAREN P. HEWITT, United States Attorney, and DAVID L. KATZ, Assistant United States Attorney, hereby move this for an extension of time to file it's Response and Opposition to Defendants Motions to Dismiss. The reason for this request is that Defendant's motions to dismiss were filed only ten days ago, on July 20, 2008, and Government counsel needs more time to review voluminous A-file, tape recordings of several deportation hearings before immigration courts, documentation and to conduct research of technical immigration issues. Further, Government counsel just completed a lengthy filing with the Ninth Circuit. That motion response required a detailed review of the record of a case that has been ongoing since November 2006. The Government requests that the due date for it's response to Defendant's motions be extended to August 11, 2008, which will give Defendant time to file any reply to the Government's

Case 3:07-cr-03472-WQH

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Filed 07/30/2008

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Response before the hearing on August 18, 2008. Government counsel has spoken with Michael Berg, counsel for Defendant Gonzalez-Ruiz. Mr. Berg has no opposition to the date for the filing of the Government's response be extended to August 11, 2008. DATED: July 30, 2008 Respectfully submitted, KAREN P. HEWITT United States Attorney s/David L. Katz DAVID L. KATZ Assistant U.S. Attorney

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Case 3:07-cr-03472-WQH

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Filed 07/30/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) RODOLFO GONZALEZ-RUIZ, ) ) Defendants. ) ) 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 the Case No. 07cr3472-WQH

CERTIFICATE OF SERVICE

GOVERNMENT'S REQUEST FOR EXTENSION OF TIME TO FILE ITS RESPONSE & OPPOSITION TO DEFENDANT'S MOTIONS TO DISMISS 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. Michael Berg 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: 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 July 30, 2008

s/David L. Katz DAVID L. KATZ