Free Motion to Continue - District Court of California - California

Case 3:07-cr-03245-BEN

Document 31

Filed 05/15/2008

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FRANCISCO J. SANCHEZ JR. 550 West C St, Suite 1670 San Diego, California 92101 Telephone: (619) 232-8000 Facsimile: (619) 237-8898 Attorneys for Defendant EZEQUIEL LOPEZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiffs, v. EZEQUIEL LOPEZ and ARMANDO REGALADO-NARANJO Defendant.

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CRIMINAL CASE NO.: 07CR3245-BEN JOINT MOTION TO CONTINUE MOTION HEARING FROM MAY 16, 2008 TO JUNE 23, 2008 Hearing Date: May 16, 2008 Time: 2:00 p.m. Judge: Roger T. Benetiz

NOTICE IS HEREBY GIVEN THAT: Defendant EZEQUEIL LOPEZ ( hereinafter "LOPEZ") by and through his attorney of record Francisco J. Sanchez, Jr. and Defendant, ARMANDO REGALADO-NARANJO (hereinafter "REGALADO-NARANJO"), by and through his attorney of record, Manuel L. Ramirez, Esq. of The Ramirez Law Firm; and Plaintiff, United States of America, by and through Assistant United States Attorney Jill Burkhardt, jointly move this Honorable Court to continue the current motion date of May 16, 2008 to June 23, 2008. The grounds for the instant joint motion are as following: 1. All parties herein mentioned need additional time to review and analyze new discovery that has recently been produced;

JOINT MOTION TO CONTINUE MOTION HEARING 1

Case 3:07-cr-03245-BEN

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Filed 05/15/2008

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2. REGALADO-NARANJO, LOPEZ and the Government also need additional time to meet, discuss and negotiate a possible disposition of this matter in light of the newly produced discovery; 3. The Government and both Defendants believe that it will be in the best interest of judicial and law enforcement economy to continue the motion hearing to the date requested. CONCLUSION Based on the above, it is respectfully requested that the instant Joint Motion to Continue the Motion Hearing date be granted.

Dated: May 16, 2008 By:

THE RAMIREZ LAW FIRM /s/ MANUEL L. RAMIREZ Manuel L. Ramirez, Esq. Attorneys for Defendant, ARMANDO REGALADO-NARANJO

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FRANCISCO J. SANCHEZ, JR. /s/ FRANCISCO J. SANCHEZ, JR. Francisco J. Sanchez, Jr. Esq. Attorney for Defendant EZIQUIEL LOPEZ

UNITED STATES ATTORNEY KAREN P. HEWITT

/s/ JILL BURKHARDT Jill Burkhardt, Esq. Assistant U.S. Attorney,

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