Free Motion for Order - District Court of California - California

Case 3:07-cr-03080-L

Document 17

Filed 02/14/2008

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1 LEILA W. MORGAN

California State Bar No. 232874
2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, California 92101-5008 Telephone: (619) 234-8467 Ext. 3737 4 Facsimile: (619) 687-2666 [email protected] 5 6 Attorneys for Mr. Vega 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3080-L

11 UNITED STATES OF AMERICA, 12 13 v. 14 JORGE ALBERTO VEGA, 15 16 17 TO: 18 19 Defendant. Plaintiff,

JOINT MOTION TO CONTINUE SENTENCING HEARING

KAREN HEWITT, UNITED STATES ATTORNEY; CARLOS ARGUELLO, ASSISTANT UNITED STATES ATTORNEY; FRANCISCO TORRES, UNITED STATES PROBATION OFFICER. Jorge Vega, by and through his attorneys, Leila W. Morgan and Federal Defenders of San Diego,

20 counsel for Mr. Vega jointly moves with Assistant United States Attorneys Carlos Arguello, that the 21 sentencing hearing currently set for February 19, 2008, at 8:30 a.m. be continued until March 24, 2008, at 22 8:30 a.m. There are several sentencing issues that counsel needs to resolve with the client prior to being 23 prepared to go forward with the sentencing. Mr. Vega is currently in the custody of the U.S. Marshalls. The 24 parties also agree that time should be excluded under the speedy trial act. 25 // 26 // 27 // 28 //

Case 3:07-cr-03080-L

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For the foregoing reasons, the parties jointly request that the sentencing hearing be continued until

2 March 24, 2008, at 8:30 a.m. 3 4 Dated: February 14, 2008 5 6 7 Dated: February 14, 2008 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3080-L /s/ Carlos Arguello CARLOS ARGUELLO Assistant United States Attorney [email protected] /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Mauleon [email protected]

Case 3:07-cr-03080-L

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her

3 information and belief, and that a copy of the foregoing document has been served this day upon: 4 Carlos Arguello 5 U S Attorneys Office Southern District of California Civil Division 6 880 Front Street Suite 6253 7 San Diego, CA 92101 (619)557-5662 8 Fax: (619)235-2757 Email: [email protected] 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 07cr3080-L Dated: February 14, 2008 /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Mr. Vega [email protected]