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

Case 3:07-cr-03267-JLS

Document 28

Filed 05/10/2008

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KAREN P. HEWITT United States Attorney STEVEN DE SALVO Assistant U.S. Attorney California State Bar No. 199904 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7032/(619) 235-2757 (Fax) Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) Criminal Case No. 07CR3267-JLS ) ) APPLICATION FOR ORDER ) SHORTENING TIME ) ) ) ) ) )

UNITED STATES OF AMERICA, Plaintiff, v. GUADENCIO CAYETANOCAMACHO, Defendants.

COMES NOW the plaintiff, United States of America, by and through its counsel, Karen P. Hewitt, United States Attorney, and Steven De Salvo, Assistant United States Attorney, and hereby moves this Court for an order shortening time to permit the Government to file its Response and Opposition to Defendant's Supplemental Motion to Dismiss the Indictment. The grounds for this application are set forth in the attached declaration of counsel. DATED: May 10, 2008 Respectfully submitted, KAREN P. HEWITT United States Attorney s/Steven De Salvo ___________________________ STEVEN DE SALVO Assistant United States Attorney Attorneys for Plaintiff

Case 3:07-cr-03267-JLS

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Filed 05/10/2008

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DECLARATION OF STEVEN DE SALVO 1 I, Steven De Salvo, hereby declare as follows: 2 1. 3 2. 4 15, 2008, at 1:30 p.m. 5 3. The defense filed its Motion to Dismiss the Indictment and Suppress Statements on 6 April 24, 2008. Under the local rules, the response of the United States should have been filed, at 7 the latest, on May 1, 2008, which is 14 days prior to the Motion Hearing. 8 5. Due to the complexity of issues presented by Defendant's motion, one week was 9 insufficient time for the United States to prepare its response. Accordingly, the Unites States 10 respectfully requests that the Court allow the Government's response to be filed late, on May 10, 11 2008. 12 Dated: May 10, 2008 13 14 15 16 17 18 19 22 23 24 25 26 27 28 ___________________________ STEVEN DE SALVO Assistant U.S. Attorney /s/ Steven De Salvo I am assigned to the above-captioned case, which is set for a Motion Hearing on May I am an Assistant United States Attorney for the Southern District of California.

Case 3:07-cr-03267-JLS

Document 28

Filed 05/10/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) Criminal Case No. 07CR3267-JLS ) Plaintiff, ) ) CERTIFICATE OF SERVICE v. ) ) GUADENCIO CAYETANO-CAMACHO, ) ) Defendant. ) ) IT IS HEREBY CERTIFIED THAT: I, STEVEN DE SALVO, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of GOVERNMENT'S RESPONSE AND OPPOSITION TO DEFENDANT'S SUPPLEMENTAL MOTION TO DISMISS THE INDICTMENT on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System. Hanni Fakhoury 225 Broadway, Suite 900 San Diego, CA 92101 [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on May 10, 2008. s/ Steven De Salvo STEVEN DE SALVO

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