Free Motion to Continue - District Court of California - California

Case 3:07-cr-02918-H

Document 49

Filed 01/22/2008

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Scott Savary (SBN 174297) SAVARY, APC 205 West Date Street San Diego, CA 92101 619 231-4276 f.888 300 4339 Attorney for DEFENDANT VELASQUEZ,

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. ALEJANDRO LOPEZ (1) EMILIO LOPEZ (2) RAVINDERJIT SINGH SEKHON (3) LINDA VELASQUEZ(4), Defendants.

) Case No.: 07CR2918-W ) ) JOINT MOTION TO CONTINUE ) SENTENCING HEARING ) ) ) ) ) ) ) ) ) ) ) )

IT IS HERREBY REQUESTED by the parties in the case, Plaintiff, United States of America, by and through it's counsel, Karen P. Hewitt, United States Attorney, and Valerie Chu, Assistant United States Attorney, and the Defendant, Linda Velasquez, by and through her counsel, Scott Savary, that the sentencing hearing in the above entitled case scheduled for February 4, 2008 at 9:00 a.m., be continued to March 10, 2008 at 9:00 a.m. for Ms. Velasquez.

JOINT MOTION TO CONTINUE SENTENCING HEARING - 1

Case 3:07-cr-02918-H

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The parties agree that the time between February 4, 2008 and March 10, 2008 is excludable under the Speedy Trial Act for acceptance of plea. The undersigned defense attorney for Ms. Velasquez called the courtroom to obtain the new date and the new date is agreeable to both parties. A proposed order with respect to this motion is being submitted directly to the Court via [email protected]. Defendant Velasquez is out of custody on bond. An

acknowledgement of the next court date is being filed contemporaneously with this joint motion.

Dated: January 21, 2008

By: s/Scott Savary Attorney for Deft. Velasquez [email protected]

Dated: January 21, 2008

By: s/Valerie Chu Asst. US Attorney Email: Valerie [email protected]

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Case 3:07-cr-02918-H

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Scott Savary (SBN 174297) SAVARY, APC 205 West Date Street San Diego, CA 92101 619 231-4276 f.888 300 4339 Attorney for DEFENDANT VELASQUEZ,

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. ALEJANDRO LOPEZ (1) EMILIO LOPEZ (2) RAVINDERJIT SINGH SEKHON (3) LINDA VELASQUEZ(4), Defendants.

) Case No.: 07CR2918-W ) ) CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) ) ) ) )

It is hereby certified that: I, Scott Savary, am a citizen of the United States and am at least 18 years of age. My business address is 205 West Date Street, San Diego, CA 92101. I have caused service of JOINT MOTION TO CONTINUE SENTENCING HEARING on the following parties by electronically filing the foregoing with the Clerk of the District Court using it's ECF system, which electronically notifies them.

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Case 3:07-cr-02918-H

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Filed 01/22/2008

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Valerie Chu [email protected], [email protected], [email protected]

Ezekiel E. Cortez [email protected], [email protected] Gregory Vega [email protected], [email protected] Kurt David Hermansen [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on January 21, 2008 By: s/Scott Savary Attorney for Deft. Velasquez [email protected]

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