Free Motion to Continue - District Court of California - California

Case 3:07-cr-03144-BTM

Document 30

Filed 04/08/2008

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FRANCISCO J. SANCHEZ, JR. Attorney at Law California State Bar No. 220284 550 West C Street, Ste. 1670 San Diego, CA 92101 Telephone: (619) 232-8000 Facsimile: (619) 237-8898 Attorney for Defendant Oscar Rodriguez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. OSCAR RODRIGUEZ, Defendant.

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Case No.: 07 CR 3144-BTM STIPULATION TO CONTINUE SENTENCING HEARING TO MAY 30, 2008 Date: April 10, 2008 Time: 9:00 a.m. Judge: Barry Ted Moskowitz

IT IS HEREBY STIPULATED by and between Defendant OSCAR RODRIGUEZ (hereinafter "Mr. RODRIGUEZ"), by and through his attorney of record, Francisco J. Sanchez, Jr. and Plaintiff United States of America, by and through Assistant United States Attorney Carlos Arguello, that Mr. Rodriguez' Sentencing Hearing be continued from April 10, 2008 at 9:00 a.m. to May 30, 2008 at 9:00 a.m. on the following grounds:

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Case 3:07-cr-03144-BTM

Document 30

Filed 04/08/2008

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1.

Undersigned has been contacted by defendants family who wish to supplement defendants sentencing memorandum with character letters;

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Based on the need to review these documents with Mr. Rodriguez and properly address their contents, undersigned counsel respectfully requests additional time to prepare for this sentencing hearing;

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Undersigned counsel has contacted AUSA Carlos Arguello and he has no objection to this request;

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4. 5.

Defendant is out of custody; Both government counsel and defense counsel agree that time will be excluded under the Speedy Trial Act until the acceptance of plea.

IT IS SO STIPULATED.
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Dated: April 8, 2008

FRANCISCO J. SANCHEZ, JR. ESQ

By /s/ Francisco J. Sanchez, Jr. Francisco J. Sanchez, Jr. Attorney for Defendant Oscar Rodriguez

Dated: April 8, 2008

KAREN HEWITT United States Attorney

By /s/ Carlos Arguello Carlos Arguello Assistant United States Attorney

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