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

Case 3:07-cr-03279-IEG

Document 12

Filed 01/07/2008

Page 1 of 1

1 2 3 4

Debra R. Torres-Reyes 1901 First Ave., Ste 152 San Diego, California 92101 (619) 237-7891 (619) 237-1156 Fax [email protected] Attorney For Ivan Flores

5 6 UNITED STATES DISTRICT COURT 7 SOUTHERN DISTRICT OF CALIFORNIA 8 (HONORABLE IRMA E. GONZALEZ) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES OF AMERICA ) ) Plaintiff, ) ) v, ) ) IVAN FLORES, ) ) Defendant. ) ) ) ____________________________________) CASE NO. : 07CR-3279-IEG EX PARTE APPLICATION FOR ORDER SHORTENING TIME

Defendant Ivan Flores through his attorney, Debra R. Torres-Reyes makes application for an order shortening time by one week in which to file his Notice of Motions and Motion for Discovery and Leave to File Further Motions so that Mr. Flores' Motion may be filed on January 7, 2008. The Motions Hearing date is scheduled for January 14, 2008 at 2:00 p.m. before the Honorable Irma E. Gonzalez. This application for an order shortening time is necessary as these motions were not completed in a timely manner due to a calendar mistake during the Holidays. For the foregoing reasons, counsel requests the Court sign the order shortening time. Dated: January 7, 2008 Respectfully submitted, s/ Debra R. Torres-Reyes Debra R. Torres-Reyes Attorney for Defendant Flores