Free Motion to Continue - District Court of California - California

Case 3:07-cr-03087-DMS

Document 34

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. ) ) ) ) ) ) ) ) ) ) Case No. 07CR3087-DMS NOTICE OF JOINT MOTION TO CONTINUE SENTENCING HEARING

TO:

KAREN HEWITT, UNITED STATES ATTORNEY, CHRISTINA McCALL, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that the defendant, Loni Rose Romero, by and through

her counsel, Jami L. Ferrara, Esq., is asking this Court to enter an order granting the following joint motion to continue the sentencing hearing scheduled for Friday, February 15, 2008 at 9:00 a.m. to Friday, April 11, 2008 at 9:00 a.m.. // // // // // //

Case 3:07-cr-03087-DMS

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Filed 01/30/2008

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MOTION The defendant, Loni Rose Romero, by and through her attorney, Jami L. Ferrara, Esq., jointly with the plaintiff, the United States of America, pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to continue the sentencing hearing scheduled for Friday, February 15, 2008 at 9:00 a.m. to Friday, April 11, 2008 at 9:00 a.m.. This motion is based upon the instant motion and notice of motion, the attached statement of facts and memorandum of points and authorities, and all other materials that may come to this Court's attention at the time of the hearing on these motions. 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

Case 3:07-cr-03087-DMS

Document 34

Filed 01/30/2008

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PROOF OF SERVICE I, Jami L. Ferrara, do hereby state: I am a citizen of the United States and a resident of the County of San Diego, State of California. I am over the age of eighteen years, and am not a party to the within action. My business address is 964 Fifth Avenue, Suite 335, San Diego, California 92101. On the this 29th day of January 2008, I served the within JOINT MOTION TO CONTINUE SENTENCING HEARING in Case No. 07CR3087-DMS electronically through the CM/ECF system for the Southern District of California on the United States Attorney's Office, AUSA Christina McCall, specifically, a registered user of the CM/ECF system. I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct. EXECUTED this day, 29 January 2008, at San Diego, California.

S/Jami L. Ferrara
JAMI L. FERRARA

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07CR3087