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

Case 3:07-cr-03474-WQH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 v.

Document 5

Filed 02/19/2008

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SHAFFY MOEEL California Bar No. 238732 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 685-3714 [email protected] Attorneys for Mr. Herrera

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) Case No. 07CR3474-WQH Date: February 25, 2008 Time: 2:00 p.m. MOTION FOR ORDER TO SHORTEN TIME

JOSE SALVADOR HERRERA-TAPIA, Defendant.

The above-named defendant, by and through counsel, moves this Court for an order shortening 16 time in his attached NOTICE OF MOTIONS AND MOTIONS TO COMPEL DISCOVERY AND LEAVE 17 TO FILE FURTHER MOTIONS fourteen (14) days, to be heard on February 25, 2008, at 2:00 pm. or as 18 soon thereafter as counsel may be heard for the following reasons: 19 Counsel miscalendared this motion hearing date and only realized her mistake today. Counsel 20 is aware of this Court's rules requiring the filing of motions three weeks in advance of the set motion hearing 21 date. Counsel assures this Court that it is not her practice to file pleadings or papers in an untimely manner. 22 Counsel apologizes to this Court and all parties and requests that this Court grant her motion for an order 23 shortening time. Counsel will hand deliver a courtesy copy to the Assistant United States Attorney David 24 Leshner. 25 Respectfully submitted, 26 27 28 Dated: February 19, 2008 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Herrera 1

Case 3:07-cr-03474-WQH 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 Dated: February 19, 2008

Document 5

Filed 02/19/2008

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her information and belief, and that a copy of the foregoing document has been served this day upon: U S Attorney CR [email protected]

/s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467 (tel) (619) 687-2666 (fax) e-mail: [email protected]

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