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

Case 3:07-cr-03279-IEG

Document 26

Filed 04/16/2008

Page 1 of 2

1 DEBRA R. TORRES-REYES California Bar No. 146724 2 LAW OFFICES OF DEBRA R. TORRES-REYES 1901 First Ave., First Floor 3 San Diego, Ca 92101 Telephone: (619) 237-7891 4 Fax: (619) 237-8899 email: [email protected] 5 Attorney for Mr. Ivan Antonio Flores 6 7 8 9 10 11 12 13 14 15 16 The defendant, IVAN ANTONIO FLORES, by and through counsel, Debra R. 17 Torres-Reyes, moves this Court for an order shortening time to file Defendant's 18 SENTENCING SUMMARY CHART AND SENTENCING EXHIBIT on today's date , 19 April 16, 2008. Said documents were due to be filed on Monday, April 14, 2008 . 20 Counsel has been waiting for additional sentencing documents and has only received 21 one document to date. Mr. Flores' Sentencing Summary Chart and Sentencing Exhibit do 22 not require a response from United States Attorney's Office nor U.S. Probation, thus 23 neither are not prejudiced by the late filing. 24 Respectfully submitted, 25 Dated: April 16, 2008 26 27 28 /s Debra R. Torres-Reyes Debra R. Torres-Reyes Attorney for Defendant Ivan Antonio Flores ) ) Plaintiff, ) ) v. ) ) IVAN ANTONIO FLORES, ) ) Defendant. ) ____________________________________) UNITED STATES OF AMERICA, Criminal Case No.07CR-3279-IEG MOTION TO SHORTEN TIME TO FILE DEFENDANT'S SENTENCING SUMMARY CHART AND EXHIBIT DATE: TIME: CTRM: April 21, 2008 2:00 p.m. 4th , 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. IRMA E. GONZALEZ)

Case 3:07-cr-03279-IEG

Document 26

Filed 04/16/2008

Page 2 of 2

1

PROOF OF SERVICE

2 I , Debra R. Torres-Reyes, declare as follows: 3 4 5 92101. 6 7 8 I am not a party to the above entitled action. On April 16, 2008 , I hereby caused service of Defendant's Ex parte Motion to Shorten I am a citizen of the United States and employed in the City of San Diego, California. I am over eighteen years of age. My business address is 1901 First Ave., First Floor San Diego, California,

9 Time to File Sentencing Summary Chart and Exhibit by Electronically filing the foregoing with 10 the Clerk of the District Court using its ECF System, which electronically notifies them and to the 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 April 16, 2008 /s/DebraR. Torres-Reyes Debra R. Torres-Reyes [email protected] [email protected]. I declare under penalty of perjury that the foregoing is true and correct. United States Attorney's Office for The Southern District of California at