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

Case 3:07-cr-03213-BEN

Document 14

Filed 02/29/2008

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GARY P. BURCHAM California State Bar No. 190780 2 964 Fifth Avenue, Suite 300 San Diego, CA 92101 3 Telephone: (619) 699-5930
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Attorney for Rosendo Rodriguez-Gonzalez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) UNITED STATES OF AMERICA, Plaintiff, v. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3213-BEN Date: March 10, 2008 Time: 2:00 p.m. APPLICATION FOR ORDER SHORTENING TIME FOR FILING OF MOTION TO DISMISS INDICTMENT

ROSENDO RODRIGUEZ-GONZALEZ, Defendant.

The above-named defendant, by and through his counsel, moves this Court for an order shortening time to file Defendant's Motion to Dismiss Indictment to ten days, to be heard Monday, March 10, 2008, at 2:00 p.m., or as soon thereafter as counsel may be heard, for the following reasons: The A-file documents that were required to write this motion were not available to counsel until approximately noon on February 26, 2008, and counsel was not able to complete this motion until February 29, 2008. Respectfully submitted,

DATED:

February 29, 2008

/s/ Gary P. Burcham GARY P. BURCHAM Attorney for Mr. Rodriguez

Case 3:07-cr-03213-BEN

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Filed 02/29/2008

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff-Appellee, v. ROSENDO RODRIGUEZ-GONZALEZ, ) ) ) ) ) ) ) ) ) U.S.D.C. No. 07CR3213-BEN CERTIFICATE OF SERVICE

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Defendant-Appellant.
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IT IS HEREBY CERTIFIED THAT:
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I, GARY P. BURCHAM, am a citizen of the United States and am at
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least eighteen years of age.
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My business address is 964 Fifth Avenue,

Suite 300, San Diego, CA 92101. I am not a party to the above-entitled action.
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I have caused

service of Defendant's Application for Order Shortening time on the following party or parties by electronically filing the foregoing with the
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Clerk of the District Court using its ECF System, which electronically
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notifies him/her.
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Eugene Litvinoff, Esq. Border Crimes Unit 880 Front Street San Diego, CA 92101 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 29, 2008. /s/ Gary P. Burcham GARY P. BURCHAM

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Case 3:07-cr-03213-BEN

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Filed 02/29/2008

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