Free Motion to Continue - District Court of California - California

Case 3:07-cr-03106-BEN

Document 42

Filed 09/16/2008

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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 Ms. Vasquez 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3106-BEN

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

JOINT MOTION TO CONTINUE SENTENCING HEARING

KAREN HEWITT, UNITED STATES ATTORNEY; MICHELLE PETTIT, ASSISTANT UNITED STATES ATTORNEY. Maria Vasquez, by and through her attorneys, Leila W. Morgan and Federal Defenders of San Diego,

20 counsel for Ms. Vasquez jointly moves with Assistant United States Attorney Michele Pettit, that the 21 Sentencing Hearing currently scheduled for September 22, 2008, at 9:00 a.m. be continued until December 22 15, 2008, at 9:00 a.m. The parties are currently attempting to resolve several issues prior to the sentencing 23 hearing. Ms. Vasquez is currently on bond, a signed acknowledgment of next court date will be filed as soon 24 as possible. The parties agree that time should be excluded under the speedy trial act. 25 26 Dated: September 16, 2008 27 28 /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]

Case 3:07-cr-03106-BEN

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1 Dated: September 16, 2008 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

/s/ Michelle Pettit MICHELLE PETTIT Assistant United States Attorney [email protected]

Case 3:07-cr-03106-BEN

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CERTIFICATE OF SERVICE

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

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