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

Case 3:07-cr-03012-BTM

Document 22

Filed 01/24/2008

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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 Soliz-Valdez

UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HON. BARRY TED MOSKOWITZ) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 07CR3012-BTM DATED: January 24, 2007 /s/ Gerard J. Wasson GERARD J. WASSON, ESQ. Attorney for Jose Soliz-Valdez The defendant, Jose Soliz-Valdez, by and through counsel, Gerard J. Wasson, hereby moves this Court for an order shortening time to file DEFENDANT'S SENTENCING MEMORANDUM on Thursday, January 24, 2008. The reason for this motion is because the parties have requested that the sentencing hearing be advanced on the calendar due to the joint recommendation for a "time served" sentence. Government Counsel has been provided a courtesy copy of this pleading. TO: v. JOSE ALEXIS SOLIZ-VALDEZ, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3012-BTM Date: January 25, 2008 Time: 2:00 p.m. MOTION FOR ORDER SHORTENING TIME TO FILE DEFENDANT'S SENTENCING MEMORANDUM

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

Case 3:07-cr-03012-BTM

Document 22

Filed 01/24/2008

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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 Soliz-Valdez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. ) ) ) ) ) ) ) ) ) Crim. No. 07CR3012-BTM

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CERTIFICATE OF SERVICE

JOSE ALEXIS SOLIZ-VALDEZ, 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 Soliz-Valdez's Motion for Order Shortening Time to File his Sentencing Memorandum 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 January 24, 2008. /s/ Gerard J. Wasson GERARD J. WASSON, ESQ.