Free Motion to Continue - District Court of California - California

Case 3:07-cr-03163-DMS

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Filed 07/11/2008

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1 Inge Brauer Attorney at Law 2 State Bar No. 68701 2240 F Street 3 San Diego, CA 92102 Telephone: (619) 238-1031 4 Facsimile: (619) 238-0930 5 6 7 8 9 Attorney for JOSE GONZALEZ ALVAREZ UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) ) ) ) ) ) ) ) ) ) ) Case No.: 07CR3163-DMS STIPULATION TO CONTINUE SENTENCING HEARING AND ORDER THEREON

10 UNITED STATES OF AMERICA, 11 12 v. 13 JOSE GONZALEZ ALVAREZ, 14 15 16 Defendant. Plaintiff,

IT IS HEREBY STIPULATED AND AGREED BETWEEN THE PARTIES, that

17 for good cause, the sentencing hearing in the above-mentioned case, 18 should be continued from July 11, 2008 at 9:00 a.m. to July 18, 2008, 19 at 9:00 a.m. 20 21 22 Dated: 23 24 25 26 27 28 Dated: LAWRENCE CASPER Assistant United States Attorney INGE BRAUER, Attorney for Defendant JOSE GONZALEZ ALVAREZ The defendant is in custody.

SO STIPULATED.

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Case 3:07-cr-03163-DMS

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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) ) ) ) ) ) ) ) ) ) ) Case No.: 07CR3163-DMS

9 UNITED STATES OF AMERICA, 10 11 Plaintiff, v.

12 JOSE GONZALEZ ALVAREZ, 13 14 15 Defendant.

ORDER TO CONTINUE SENTENCING HEARING

IT IS HEREBY ORDERED, that the sentencing hearing may be

16 continued from July 11, 2008, at 9:00 a.m. to July 18, 2008 at 9:00 17 a.m. 18 19 20 Dated: 21 22 23 24 25 26 27 28 HONORABLE DANA M. SABRAW United States District Judge SO ORDERED.

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Case 3:07-cr-03163-DMS

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Filed 07/11/2008

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1 Inge Brauer Attorney at Law 2 State Bar No. 68701 2240 F Street 3 San Diego, CA 92102 Telephone: (619) 238-1031 4 Facsimile: (619) 238-0930 5 6 Attorney for JOSE GONZALEZ ALVAREZ 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) ) ) ) ) ) ) ) ) ) ) Case No.: 07CR3163-DMS DECLARATION OF COUNSEL IN SUPPORT OF REQUEST FOR CONTINUANCE OF SENTENCING HEARING

11 UNITED STATES OF AMERICA, 12 13 v. 14 JOSE GONZALEZ ALVAREZ, 15 16 17 18 state: 19 1) Defendant. Plaintiff,

I, Attorney Inge Brauer, after having been duly sworn, depose and

I am an attorney at law duly licensed to practice before all

20 of the courts of the State of California, the United States District 21 Court for the Southern District of California, and the United States 22 Court of Appeals for the Ninth Circuit; and the United States Supreme 23 Court; 24 25 26 27 28 /// 3) 4) 2) I am the appointed counsel of record for defendant, JOSE GONZALEZ ALVAREZ. Counsel needs to have further investigation done on the case. Both parties agree to continue the sentencing hearing.

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Case 3:07-cr-03163-DMS

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5)

The new sentencing date has been cleared with the courtroom deputy.

Therefore, it is respectfully requested that the Court continue

4 JOSE GONZALEZ ALVAREZ's sentencing hearing date from July 11, 2008 at 5 9:00 a.m. to July 18, 2008 at 9:00 a.m. 6 Executed under penalty of perjury on June 12th, 2005 at San

7 Diego, California. 8 9 Dated: ______________ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _______________________________ Inge Brauer

07CR3163