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

Case 3:07-cr-03056-WQH

Document 18

Filed 12/10/2007

Page 1 of 1

1 JASON I. SER

California State Bar No. 201816
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

225 Broadway, Suite 900
3 San Diego, California 92101-5008

Telephone: (619) 234-8467
4 [email protected] 5 Attorneys for Mr. Bierly 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) ) ) ) ) ) ) ) ) ) ) Case No. 07cr3056-WQH Date: December 17, 2007 Time: 2:00 p.m. MOTION FOR ORDER TO SHORTEN TIME

11 UNITED STATES OF AMERICA, 12 13 v. 14 STEVEN BIERLY (2), 15 16

Plaintiff,

Defendant. TO:

17 18

KAREN HEWITT, UNITED STATES ATTORNEY; AND PAUL COOK, ASSISTANT UNITED STATES ATTORNEY: The above-named defendant, by and through counsel, moves this Court for an order shortening time

19 to file his MOTIONS to seven (7) day, to be heard Monday, December 17, 2007 at 2:00 p.m., or as soon 20 thereafter as counsel may be heard, for the following reasons: 21

Defense counsel was unable to prepare the motions in a timely fashion because he was out of the

22 district beginning November 19, 2007, and did not return until last Thursday, December 6, 2007. Prior to 23 leaving, counsel had been preparing an emergency appellate brief in United States v. Bristow, which was 24 completed the day before his departure from the district. Since returning, counsel has been drafting another 25 emergency appellate brief in a second case, United States v. Barrios, due this week to the Ninth Circuit. 26 27 28 DATED: December 10, 2007

Respectfully submitted,

JASON I. SER Federal Defenders of San Diego, Inc. Attorneys for Mr. Bierly