Free Motion to Continue - District Court of California - California

Case 3:07-cr-03181-DMS

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Filed 03/17/2008

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KAREN P. HEWITT United States Attorney TIMOTHY F. SALEL Assistant U.S. Attorney California State Bar No. 163597 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone No.: (619) 557-6074 E-mail: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ARACELI RAMIREZ-VARELA, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07CR3181-DMS JOINT MOTION TO CONTINUE DATE FOR ACCEPTANCE OF PLEA AND SENTENCING DATE: TIME: April 4, 2008 9:00 a.m.

IT IS HEREBY REQUESTED by and between the parties, plaintiff, United States of America, by and through its counsel Karen P. Hewitt, United States Attorney, and Timothy F. Salel, Assistant U.S. Attorney, and Frank A. Balistrieri, counsel on behalf of defendant, that the hearing for acceptance of plea and sentencing be continued from April 4, 2008 at 9:00 a.m. to June 6, 2008 at 9:00 a.m. The parties agree that time shall be excluded under the Speedy Trial Act until the plea is accepted. All terms and conditions of the bond shall remain in effect and the defendant agrees to file a written acknowledgment of the next court date. The undersigned Assistant U.S. Attorney spoke with the Court's Courtroom Deputy, Jamie Klosterman, to obtain the new date, and that date is agreeable to both parties.

Case 3:07-cr-03181-DMS

Document 25

Filed 03/17/2008

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A proposed order regarding the continued date for acceptance of plea and sentencing will be submitted directly to the Court via: [email protected]. Respectfully submitted, KAREN P. HEWITT United States Attorney DATED: March 17, 2008 /S/ TIMOTHY F. SALEL TIMOTHY F. SALEL Assistant U.S. Attorney /S/ FRANK A. BALISTRIERI FRANK A. BALISTRIERI Attorney for Defendant

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07CR3181-DMS

Case 3:07-cr-03181-DMS

Document 25

Filed 03/17/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ARACELI RAMIREZ-VARELA, Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 07CR3181-DMS

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that: I, Timothy F. Salel, am a citizen of the United States over the age of 18 years and a resident of San Diego County, CA; my business address is 880 Front Street, San Diego, CA 92101-8893; I am not a party to the above-entitled action. I have caused service of JOINT MOTION TO CONTINUE DATE FOR ACCEPTANCE OF PLEA AND SENTENCING, on the following party, by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies the following party: Frank A. Balistrieri - Attorney For Defendant at the following e-mail address: [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed: March 17, 2008 /s/ TIMOTHY F. SALEL TIMOTHY F. SALEL Assistant U.S. Attorney E-mail: [email protected]

07CR3181-DMS