Free Motion to Continue - District Court of California - California

Case 3:07-cr-03055-L

Document 8

Filed 01/03/2008

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KAREN P. HEWITT United States Attorney STEWART M. YOUNG Assistant U.S. Attorney California State Bar No. 234889 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-6228 / (619) 235-2757(Fax) Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. JUAN MANUEL TORRES-GOMEZ, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 3:07-CR-3055-L DATE: January 7, 2008 TIME: 2 p.m. JOINT MOTION TO CONTINUE MOTION HEARING DATE

NOW COMES plaintiff United States of America, by and through its counsel, U.S. Attorney Karen P. Hewitt and Assistant U.S. Attorney Stewart M. Young, and defendant Juan Manuel Torres-Gomez, by and through his counsel John Ellis, and herein jointly request this Court to continue the motion hearing currently set for January 7, 2008, at 2 p.m., to January 28, 2008, at 2 p.m. The basis for this request is that the defense and the prosecution are involved in negotiations, as well as the fact that the prosecutor was recently assigned to this case. DATED: January 3, 2008. Respectfully submitted, Karen P. Hewitt United States Attorney s/Stewart M. Young___________ Stewart M. Young Assistant United States Attorney Attorneys for Plaintiff United States of America s/ John Ellis John Ellis, Esq. [email protected] Attorney for Defendant Juan Manuel Torres-Gomez

Case 3:07-cr-03055-L

Document 8

Filed 01/03/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

3 4 UNITED STATES OF AMERICA, 5 Plaintiff, 6 v. 7 JUAN MANUAL TORRES-GOMEZ, 8 Defendant. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 1. John Ellis, Esq. [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on January 3, 2008. s/ Stewart M. Young Stewart M. Young I am not a party to the above-entitled action. I have caused service of the Joint Motion to Continue Motion Hearing on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. IT IS HEREBY CERTIFIED THAT: I, Stewart M. Young, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. ) ) ) ) ) ) ) ) ) ) Case No. 07-CR-3055-L

CERTIFICATE OF SERVICE