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

Case 3:07-cr-03013-H

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Filed 02/14/2008

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GERARD J. WASSON CALIFORNIA BAR NO 166636 406 Ninth Avenue, Suite 205 San Diego, California 92101 Telephone: (619) 232-0181 Attorney for Defendant Juarez-Juarez

UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE MARILYN L. HUFF) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 07CR3013-H The defendant, Jose Luis Juarez-Juarez, by and through counsel, Gerard J. Wasson, hereby moves this Court for an order shortening time to file DEFENDANT'S DOWNWARD DEPARTURE REQUEST on Thursday, February 14, 2008. The reason for this motion is because Government Counsel has been recently re-assigned for this matter, thereby necessitating a "safety valve" meeting scheduled for Thursday, February 14, 2008, the results of which impact the extent and nature of the requested departures. Government Counsel has been provided a courtesy copy of this pleading. DATED: February 14, 2007 /s/ Gerard J. Wasson GERARD J. WASSON, ESQ. Attorney for Jose Luis Juarez-Juarez TO: v. JOSE LUIS JAUREZ-JUAREZ, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3013-H Date: February 19, 2008 Time: 9:00 a.m. MOTION FOR ORDER SHORTENING TIME TO FILE DEFENDANT'S DOWNWARD DEPARTURE REQUEST

KAREN P. HEWITT, UNITED STATES ATTORNEY, and FRED SHEPPARD, ASSISTANT UNITED STATES ATTORNEY

Case 3:07-cr-03013-H

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Filed 02/14/2008

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GERARD J. WASSON Attorney at Law California Bar No. 166636 406 Ninth Avenue, Suite 205 San Diego, California 92101 Telephone: (619) 232-0181 Attorney for Defendant Jose Luis Juarez-Juarez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ) ) ) ) ) ) ) ) ) Crim. No. 07CR3013-H

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CERTIFICATE OF SERVICE

JOSE LUIS JUAREZ-JUAREZ, Defendant. IT IS HEREBY CERTIFIED THAT:

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I, GERARD J. WASSON, am a citizen of the United States and am at least eighteen years of age. My business address is 406 Ninth Avenue, Suite 205, San Diego, California, 92101. I am not a party to the above-entitled action. I have caused service of the Defendant Jose Luis Juarez-Juarez's Motion for Order Shortening Time to File his Downward Departure Request on the following parties by electronically filing the foregoing with the clerk of the District Court using its ECF System, which electronically notifies them. Assistant United States Attorney [email protected]

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I declare under penalty of perjury that the foregoing is true and correct. Executed on February 14, 2008. /s/ Gerard J. Wasson GERARD J. WASSON, ESQ.