Free Motion to Shorten Time - District Court of California - California

Case 3:07-cr-03055-L

Document 11

Filed 01/21/2008

Page 1 of 2

1 2 3 4 5 6 7

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) 557-6741(Fax) Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT

8 SOUTHERN DISTRICT OF CALIFORNIA 9 UNITED STATES OF AMERICA, 10 Plaintiff, 11 v. 12 JUAN MANUEL TORRES-GOMEZ, 13 Defendant. 14 15 The United States moves this Court for an order shortening time to defendant's sentencing 16 memorandum to seven (7) days, to be heard January 28, 2008, at 11 a.m., or as soon thereafter as 17 counsel may be heard, for the following reason: 18 1) I have been out the district for training purposes for a substantial part of the month of 19 January, as well as for oral arguments in Pasadena this month as well. I have also recently been 20 assigned a number of pending cases due to the departure of two colleagues in the past month, and 21 therefore have been unable to submit my response to defendant's motions until recently. 22 DATED: January 21, 2008 23 24 25 26 27 28 KAREN P. HEWITT United States Attorney s/Stewart M. Young___________ Stewart M. Young Assistant United States Attorney Attorneys for Plaintiff United States of America Respectfully submitted, ) ) ) ) ) ) ) ) ) ) Criminal Case No. 3:07-CR-3055L DATE: January 28, 2008 TIME: 10 a.m. MOTION FOR ORDER SHORTENING TIME

Case 3:07-cr-03055-L

Document 11

Filed 01/21/2008

Page 2 of 2

1 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

3 4 UNITED STATES OF AMERICA, 5 Plaintiff, 6 v. 7 JUAN MANUEL TORRES-GOMEZ, 8 Defendant. 9 10 11 12 13 14 1. John Ellis, Esq. 15 2. Joe McMullen, Esq. 16 I declare under penalty of perjury that the foregoing is true and correct. 17 Executed on January 21, 2008. 18 19 20 21 22 23 24 25 26 27 28 2 s/Stewart M. Young Stewart M. Young I am not a party to the above-entitled action. I have caused service of the Motion for Order Shortening Time 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. 3:07-CR-3055 L

CERTIFICATE OF SERVICE