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

Case 3:07-cr-03086-IEG
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 v. DREW GERALD TAKACS, Defendant.

Document 23

Filed 03/24/2008

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SHAFFY MOEEL California Bar No. 238732 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 685-3714 [email protected] Attorneys for Mr. Takacs

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE IRMA E. GONZALEZ) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) Case No. 07CR3086-IEG Date: April 1, 2008 Time: 9:00 a.m. MOTION FOR ORDER TO SHORTEN TIME

The above-named defendant, by and through counsel, moves this Court for an order shortening 16 time in his attached OBJECTIONS TO PRE-SENTENCE REPORT, eight (8) days, to be heard on aPRIL 17 1, 2008, at 9:00 am. or as soon thereafter as counsel may be heard for the following reasons: 18 Counsel apologizes to the Court for this late filing. Counsel assures this Court that it is not 19 her practice to file pleadings or papers in an untimely manner. Counsel apologizes to this Court and all 20 parties and requests that this Court grant her motion for an order shortening time. Counsel will hand deliver 21 a courtesy copy to the Assistant United States Attorney David Leshner. 22 Respectfully submitted, 23 24 25 26 27 28 1 Dated: March 23, 2008 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Takacs

Case 3:07-cr-03086-IEG
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 23, 2008

Document 23

Filed 03/24/2008

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her information and belief, and that a copy of the foregoing document has been served this day upon: Eugene Litvinoff [email protected]

/s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467 (tel) (619) 687-2666 (fax) e-mail: [email protected]

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