Free Motion to Continue - District Court of California - California

Case 3:07-cr-03315-BEN

Document 48

Filed 04/16/2008

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PAUL W. BLAKE Attorney at Law State Bar #94963 4045 Bonita Road, Suite 202 Bonita, California 91902 (619) 908-6429/FAX (760) 943-0299 Attorney for Defendant ALEJANDRO SAUCEDO-VIRGEN

UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1 Joint Stipulation to C ontinue Sentencing

FOR THE SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) UNITED STATES OF AMERICA Plaintiff, vs. ALEJANDRO SAUCEDO-VIRGEN, Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 07-CR-3315-1-BEN JOINT STIPULATION TO CONTINUE SENTENCING

Comes now defendant, Alejandro Saucedo-Virgen, by and through his courtappointed attorney Paul W. Blake, hereby requests that the sentencing scheduled for May 12, 2008, at 9:00 a.m. be changed to June 30, 2008, at 9:00 a.m. I have contacted the Assistant U.S. Attorney for this matter, Christina McCall, and she has no opposition to changing the sentencing date to June 30, 2008, at 9:00 a.m. Joint agreement is signified by the undersigned. Date: April 16, 2008 /s/ Paul W. Blake PAUL W. BLAKE Attorney for Defendant Alejandro Saucedo-Virgen

Date: April 16, 2008

/s/ Christina McCall CHRISTINA McCALL, AUSA

Case 3:07-cr-03315-BEN

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1:\BLA K E\Saucedo-V irgen.jtstipcont

ORDER For good cause and with the agreement of the parties, this matter is continued pursuant to the foregoing stipulation. Defendant Saucedo's sentencing is rescheduled from May 12, 2008 at 9:00 a.m. to June 30, 2008, at 9:00 a.m.

Date:

_____________________________________ JUDGE OF THE U.S. DISTRICT COURT

2 Joint Stipulation to C ontinue Sentencing

Case 3:07-cr-03315-BEN

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of his information and belief, and that a copy of the foregoing documents: JOINT STIPULATION TO CONTINUE SENTENCING ; ORDER

was served on April 16, 2008, upon the below named parties: MAILING INFORMATION FOR A CASE 07-CR-3315-1-BEN

1.

Electronic Mail Notice List

The following are those who are currently on the list to receive email notices for this case.

Christina McCall, [email protected], [email protected]

Date: April 16, 2008

/s/ Paul W. Blake
PAUL W. BLAKE Attorney for Defendant ALEJANDRO SAUCEDO-VIRGEN 4045 Bonita Road, Suite 202 Bonita, California 91902 (619) 908-6429 (tel) (619) 578-2805 (fax) [email protected]

3 Joint Stipulation to C ontinue Sentencing