Free Motion to Continue - District Court of California - California

Case 3:07-cr-03293-JLS

Document 30

Filed 09/02/2008

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William W. Brown Bar. No. 159288 BROWN &ASSOCIATES Emerald Plaza Twentieth Floor 402 West Broadway, Suite 2010 San Diego, California 92101-3554 (619) 501-4242; (619) 374-2336 facsimile [email protected] Attorneys for: Lindsey Martine Cameron

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. JANIS L. SAMMARTINO) UNITED STATES OF AMERICA, Plaintiff, v. LINDSEY M. CAMERON, Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3293-JLS

JOINT MOTION TO CONTINUE SENTENCING HEARING; SUPPORTING DECLARATION OF COUNSEL Hearing Date: September 5, 2008 Hearing Time: 9:00 AM Courtroom: 6 (3rd Flr-JLS)

THE PARTIES JOINTLY MOVE THIS COURT for an order continuing the sentencing hearing in the above-captioned case from September 5, 2008 at 9:00 AM to October 17, 2008 at 9:00 AM. The reasons for the continuance are set forth in the Declaration of Counsel attached hereto.

Date: September 2, 2008.

__s/ William W. Brown__________ William W. Brown, BROWN & ASSOCIATES Attorneys for Lindsey M. Cameron

Date: September 2, 2008

___s/ Fred Sheppard ASSISTANT UNITED STATES ATTORNEY

JOINT MOTION TO CONTINUE SENTNCING HEARING U.S. V. CAMERON 07CR3293JLS

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Case 3:07-cr-03293-JLS

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DECLARATION OF COUNSEL IN SUPPORT OF STIPULATION TO CONTINUE SENTENCING HEARING I, William W. Brown, state: 1. I am an attorney at law duly licensed to practice before all of the courts in the State of California, the United States District Court for the Southern District of California, the United States Court of Appeals for the Ninth Circuit, and the United States Supreme Court. I am appointed under the Criminal Justice Act, 18 U.S.C. § 3006A, to represent Lindsey M. Cameron. 2. Ms. Cameron was released on bond, and the conditions of her Pre-trial Release required participation in a mental health program and resolution of all outstanding state matters. She has fulfilled the mental health program requirement and is attending counseling sessions regularly. She is also actively working to resolve all state matters and has enrolled as a full-time student. 3. In addition, I have a trial set to begin September 3, 2008 before District Court Judge Larry A. Burns and will be in trial on September 5, 2008, the date for which the sentencing hearing is currently set. The Government estimates its case-in-chief will continue up through September 8, 2008. 4. My client has no objection and will execute an acknowledgment of next court date within five days of the Court's approval of the continuance. I DECLARE, UNDER PENALTY OF PERJURY, THAT THE FOREGOING IS TRUE AND CORRECT. Date: August 26, 2008. s/ William W. Brown WILLIAM W. BROWN

JOINT MOTION TO CONTINUE SENTNCING HEARING U.S. V. CAMERON 07CR3293JLS

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Case 3:07-cr-03293-JLS

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CERTIFICATE OF SERVICE U.S. v. Cameron 07CR3293-JLS I, the undersigned, hereby certify that a copy of JOINT MOTION TO CONTINUE SENTENCING HEARING was: Filed via ECF System: I, the undersigned, hereby certify that an original of the abovereferenced document(s) was uploaded/ filed to the CM/ECF system in accordance with General Order 550 and Local Rule 49.1 and thus deposited with the Clerk of the United States District Court for the Southern District of California and delivered to Assistant United States Attorney, Fred Sheppard. Personal Service of Copy to AUSA: I, the undersigned, hereby certify that I personally delivered a true copy of the above-referenced document(s) to the receptionist of the Office of the United States Attorney for the Southern District of California for immediate delivery to Assistant United States Attorney, Fred Sheppard. Personal Service of Original to Chambers: I, the undersigned, hereby certify that I personally delivered the original of the above-referenced document(s) to the Chambers of the Honorable Janis L. Sammartino. Facsimile Service of Courtesy Copy to AUSA: I, the undersigned, caused a facsimile transmission a true copy of the above-referenced document(s) from 619-234-3655 to Fred Sheppard at the Office of the United States Attorney for the Southern District of California, facsimile machine telephone number. Facsimile Service of Courtesy Copy to Chambers: I, the undersigned, caused a facsimile transmission a true copy of the above-referenced document(s) from 619-234-3655 to the Chambers of the Honorable Janis L. Sammartino, facsimile machine telephone number. Service by Mail [CivLR5.3]: I, the undersigned, hereby certify that a true copy of the above-referenced document(s) was served upon all counsel of record by postage prepaid, firstclass, United States Postal Service mail to there last known address at: SEE ATTACHED SERVICE LIST. Executed on August 26, 2008, at San Diego, California. s/ William W. Brown

JOINT MOTION TO CONTINUE SENTNCING HEARING U.S. V. CAMERON 07CR3293JLS

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