Free Motion to Continue - District Court of California - California

Case 3:07-cr-03087-DMS

Document 34-2

Filed 01/30/2008

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JAMI L. FERRARA California State Bar Number 189109 2 Law Office of Jami L. Ferrara 964 Fifth Avenue, Suite 335 3 San Diego, California 92101 Telephone: (619) 239-4344 4 Facsimile: (619) 544-1429 Email: [email protected]
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Attorney for Ms. Romero

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) UNITED STATES OF AMERICA, Plaintiff, v. LONI ROSE ROMERO, Defendant. ) ) ) ) ) ) ) ) ) ) I. THE PARTIES JOINTLY MOVE TO CONTINUE THE SENTENCING HEARING The parties jointly move this Court to continue the Sentencing Hearing currently scheduled for Friday, February 15, 2008 at 9:00 a.m. to Friday, April 11, 2008 at 9:00 a.m.. The reason for the joint request is to accommodate defense counsel's calendar and to allow the defendant additional time to make arrangements for her family if this Court remands her into custody at the time of sentencing. // // // // // Case No. 07CR3087-DMS JOINT MOTION TO CONTINUE SENTENCING HEARING

Case 3:07-cr-03087-DMS

Document 34-2

Filed 01/30/2008

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A proposed order to this effect has been submitted to this Court by electronic mail, per the procedures for the CM/ECF System.

Respectfully submitted,

S/Jami L. Ferrara
Dated: January 30, 2008 JAMI L. FERRARA Attorney for Ms. Romero

S/Christina McCall
Dated: January 30, 2008 CHRISTINA McCALL Assistant United States Attorney

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07CR3087