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

Case 3:07-cr-03214-H

Document 9-2

Filed 01/25/2008

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RICARDO M. GONZALEZ LAW OFFICES OF RICARDO M. GONZALEZ California State Bar No. 98993 101 W. Broadway, Suite 1950 San Diego, California 92101 Telephone: (619) 238-9910 Fax: (619) 238-9914 Attorney for Defendant Carlos Quintero-Lopez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
(HONORABLE MARILYN L. HUFF) ) ) Plaintiff, ) ) v. ) ) CARLOS QUINTERO-LOPEZ, ) ) Defendant. ) _________________________________) UNITED STATES OF AMERICA, Case No. 07-CR-3214 DECLARATION OF RICARDO M. GONZALEZ IN SUPPORT OF APPLICATION FOR ORDER SHORTENING TIME

I, RICARDO M. GONZALEZ, declare as follows: I am the attorney of record for defendant Carlos Quintero-Lopez in the above entitled matter and make this declaration in support of defendant's Application for Order Shortening Time in which to file Defendant's Notice of Motion and M otion for Discovery with accompanying Memorandum of Points and Authorities in support thereof, so that defendant's discovery motion may be filed and served on January 25, 2008. The motion hearing date is scheduled for Monday, February 4, 2008, at 2:00 P.M. Defendant's motion for discovery was unable to be timely filed for the following reasons: the parties have been negotiating this case and defense believed this case would be resolved without the need to file any motions. However, the case has not yet resolved and the defense needs to file a discovery motion. Assistant United States Attorney David L. Katz has no objection to this late filing. 1 07cr3214

Case 3:07-cr-03214-H

Document 9-2

Filed 01/25/2008

Page 2 of 2

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For the foregoing reasons, it is requested that defendant's application for an order shortening time be granted so that defendant's Notice of M otion and M otion for Discovery with accompanying Memorandum of Points and Authorities in support thereof, so that it may be filed and served on January 25, 2008. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 25, 2008.

s/Ricardo M. Gonzalez RICARDO M. GONZALEZ

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