Free Motion to Continue - District Court of California - California

Case 3:07-cr-03213-BEN

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Filed 03/06/2008

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KAREN P. HEWITT United States Attorney EUGENE S. LITVINOFF Assistant U.S. Attorney California State Bar No. 214318 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-5790/(619) 235-2757 (Fax) Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ROSENDO RODRIGUEZ-GONZALEZ, ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07CR3213-BEN JOINT MOTION TO CONTINUE MOTION HEARING Date: Time: March 10, 2008 2:00 p.m.

Defendant.

IT IS HEREBY REQUESTED by the parties in the case, plaintiff, United States of America, by and through its counsel, Karen P. Hewitt, United States Attorney, and Eugene S. Litvinoff, Assistant United States Attorney, and the defendant, Rosendo Rodriguez-Gonzalez, by and through his counsel, Gary Burcham, that the motion hearing in the above entitled case scheduled for March 10, 2008 at 2:00 p.m., be continued to April 18, 2008 at 2:00 p.m. // // // // //

07CR3213-BEN

Case 3:07-cr-03213-BEN

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The undersigned Assistant United States Attorney called the court's courtroom deputy to obtain the new sentencing hearing date and that date is agreeable to all parties. A proposed order with respect to this joint motion is being submitted directly to the court via [email protected].

Date: 3/6/08

s/Eugene S. Litvinoff EUGENE S. LITVINOFF Assistant United States Attorney [email protected]

Date: 3/6/08 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

s/Gary Burcham GARY BURCHAM Attorney for Defendant

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Case 3:07-cr-03213-BEN

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3213-BEN

CERTIFICATE OF SERVICE

ROSENDO RODRIGUEZ-GONZALEZ, Defendant.

8 9 IT IS HEREBY CERTIFIED THAT: 10

I, Eugene S. Litvinoff, am a citizen of the United States and am at least eighteen years of age. 11 My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. 12 I have caused service of Government's Joint Motion to Continue Motion Hearing on the 13 following party by electronically filing the foregoing with the Clerk of the District Court using its ECF 14 System, which electronically notifies them. 15 1. 16 17 18 19 20 21 22 23 24 25 26 27 28 I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case: 1. N/A Gary Burcham

the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct. Executed on March 6, 2008 /s/Eugene S. Litvinoff Eugene S. Litvinoff

07CR3213-BEN