Free Motion to Continue - District Court of California - California

Case 3:07-cr-02918-H

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Filed 01/28/2008

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Ezekiel E. Cortez CA Bar No. 112808 The Executive Complex 1010 Second Avenue, Suite 1850, San Diego, CA 92101 Tel (619)237-0309 Fax (619)237-8052 Attorney for Defendant: Alejandro Lopez IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (THE HONORABLE MARILYN L. HUFF) UNITED STATES GOVERNMENT, ) Case No. 07CR-2918-H ) Plaintiff, ) ) JOINT MOTION TO CONTINUE vs. ) SENTENCING HEARING ALEJANDRO LOPEZ, ) ) Defendant, ) ) ) IT IS HEREBY 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 Yesmine E. Saide, Assistant United States Attorney, and Ezekiel E. Cortez, counsel for defendant, Alejandro Lopez, respectfully requesting that the sentencing hearing presently set for February 04, 2008 at 9:00 a.m. be continued until March 17, 2008 at 9:00 a.m.

The parties agree that the time between February 04, 2008 and March 17, 2008 is excludable under the Speedy Trial Act for acceptance of plea.

Joint Motion for Continuance, U.S. v. Lopez, 07CR2918-H

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Case 3:07-cr-02918-H

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Filed 01/28/2008

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The undersigned defense attorney for Alejandro Lopez contacted this Court's clerk 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 efile [email protected]. Defendant Alejandro Lopez is out of custody on bond. An acknowledgement of the next court date is being filed with this joint motion.

Dated: January 28, 2008

/S/ Signature on File by consent YESMINE E. SAIDE Assistant United States Attorney /S/ Signature on File EZEKIEL E. CORTEZ

Dated: January 28, 2008

Joint Motion for Continuance, U.S. v. Lopez, 07CR2918-H

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Case 3:07-cr-02918-H

Document 50

Filed 01/28/2008

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Ezekiel E. Cortez CA Bar No. 112808 The Executive Complex 1010 Second Avenue, Suite 1850, San Diego, CA 92101 Tel (619)237-0309 Fax (619)237-8052 Attorney for Defendant: Alejandro Lopez IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (THE HONORABLE MARILYN L. HUFF) UNITED STATES GOVERNMENT, ) Case No. 07CR-2918-H ) Plaintiff, ) ) CERTIFICATE OF SERVICE vs. ) ALEJANDRO LOPEZ, ) ) Defendant, ) ) ) I, the undersigned, hereby declare as follows: 1. I am over 18 years of age, a resident of the County of San Diego, State of California, counsel for the Defendant and that my address is 1010 Second Avenue, Suite 1850, San Diego, CA 92101; 2. That today I served the Joint Motion to Continue Sentencing Hearing on opposing counsel by causing to be delivered by e-filing to the Office of the Clerk; and that I mailed a copy to Defendant. I declare under penalty of perjury that the foregoing is true and correct.

Dated: January 28, 2008

/S/Ezekiel E. Cortez Ezekiel E. Cortez

Joint Motion for Continuance, U.S. v. Lopez, 07CR2918-H

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