Free Motion to Continue - District Court of California - California

Case 3:07-cr-02913-L

Document 19

Filed 01/03/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Baker & McKenzie LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130 +1 858 523 6200

Colin H. Murray, State Bar No. 159142 BAKER & McKENZIE LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130-3051 Telephone: +1 858 523 6200 Facsimile: +1 858 259 8290 Email: [email protected] Attorneys for Defendant JOHN K. NORRIS Karen P. Hewitt United States Attorney Mitchell D. Dembin Assistant United States Attorney Federal Office Building 880 Front Street, Room 6293 San Diego, CA 92101-8893 Telephone: +1 619 557 5558 Email: [email protected] Attorneys for Plaintiff UNITED STATES OF AMERICA UNITED STATES DISTRICT COURT SOUTHERN DISTRICT UNITED STATES OF AMERICA, Plaintiff, v. JOHN K. NORRIS, Defendant. Case No. 07CR2913-L JOINT MOTION FOR CONTINUANCE OF SENTENCING HEARING Date: Time: Judge: January 28, 2008 8:30 a.m. Hon. M. James Lorenz

On November 6, 20097, Defendant JOHN K. NORRIS entered a plea of guilty to conspiracy to commit mail fraud before Magistrate Judge Bencivengo, who set sentencing for January 28, 2008, at 8:30 a.m. Under Local Rule 32.1, the Pre-Sentence Report ("PSR") was due from Probation on December 24, 2007, which would have been thirty-five days before sentencing. Counsel for Defendant received a copy of the PSR for the first time by facsimile on January 2, 2008. As a result, Defendant now seeks additional time to review the PSR and to prepare and file objections, if any there be. In addition, the Government does not object to a reasonable continuance of the Sentencing Hearing, and there have been no prior continuances of the Sentencing Hearing. 1
Case No 07CR2913-L JOINT MOTION FOR CONTINUANCE SDODMS1/684431.1

Case 3:07-cr-02913-L

Document 19

Filed 01/03/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Baker & McKenzie LLP 12544 High Bluff Drive, Third Floor San Diego, CA 92130 Telephone: 858 523 6200

In view of the above, the plaintiff, UNITED STATES OF AMERICA, by and through its counsel, Karen Hewitt, United States Attorney, and Mitch Dembin, Assistant United States Attorney; and NORRIS, by and through his counsel, hereby ask the Court to continue the Sentencing Hearing currently scheduled for January 28, 2008, at 8:30 a.m., to February 19, 2008, at 8:30 a.m., and that time should be excluded under the Speedy Trial Act, 18 U.S.C. § 3161, to the time of NORRIS' Sentencing Hearing. Dated: January 3, 2008 BAKER & McKENZIE LLP By:/sColin H. Murray Colin H. Murray Attorneys for Defendant JOHN K. NORRIS Email: [email protected] Dated: January 3, 2008

UNITED STATES ATTORNEY By:/sMitch Dembin Assistant United States Attorney Attorney for Plaintiff UNITED STATES OF AMERICA Email: [email protected]

2
Case No 07CR2913-L JOINT MOTION FOR CONTINUANCE SDODMS1/684431.1