Free Motion to Continue - District Court of California - California

Case 3:07-cr-03026-BEN

Document 30

Filed 08/22/2008

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ALEX R. KESSEL (State Bar No. 110715) 16000 Ventura Blvd. Penthouse Suite 1208 Encino, California 91436-2746 Telephone: (818) 995-1422 Fax: (818) 788-9408 Email: [email protected]

Attorney for Defendant, STEPHANIE AVILEZ-GOMEZ

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. STEPHANIE AVILEZ-GOMEZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 07-CR-03026-BEN STIPULATION AND [PROPOSED] ORDER TO CONTINUE SENTENCING DATE Date: September 2, 2008 Time: 9:00 A.M. Courtroom: Honorable Roger T. Benitez

Defendant STEPHANIE AVILEZ-GOMEZ, by and through his attorney of record, ALEX R. KESSEL and Plaintiff, UNITED STATES OF AMERICA, by and through its counsel of record, ED WEINER, Assistant United States Attorney for the Southern District of California, hereby stipulate to the following: 1. Defendant STEPHANIE AVILEZ-GOMEZ is presently in the custody of the United States

Marshal Service. 2. On March 4, 2008, defendant STEPHANIE AVILEZ-GOMEZ plead guilty to a violation of

21 U.S.C. § 952, 960 and 963 (A)(1) pursuant to a plea agreement with the Government. 3. This matter was previously set for August 25, 2008 for sentencing and rescheduled by the

Court to September 2, 2008. Defense counsel will be engaged in a motions hearing in the matter of 1

Case 3:07-cr-03026-BEN

Document 30

Filed 08/22/2008

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the United States vs. Salvador Camacho Lopez, et al, case number CR07-00086, in the United States District Court, Eastern District in Sacramento before the Honorable Frank C. Damrell. This matter was set on the court's calendar July 17, 2008. 4. Based on the foregoing, counsel for defendant Avilez-Gomez and the Government

stipulate that the currently scheduled sentencing hearing be continued from September 2, 2008, at 9:00 a.m., to September 15, 2008, at 9:00 a.m. IT IS SO STIPULATED: DATED: August 22, 2008 Respectfully submitted,

/s/ Alex R. Kessel ALEX R. KESSEL Attorney for Defendant STEPHANIE AVILEZ-GOMEZ

IT IS SO STIPULATED: DATED: August 22, 2008 /s/ Ed Weiner ED WEINER Assistant United States Attorney for Plaintiff, UNITED STATES OF AMERICA

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