Free Motion to Continue - District Court of California - California

Case 3:08-cr-01560-JAH

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Filed 06/10/2008

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ALEX L LANDON ATTORNEY AT LAW California State Bar No. 50957 2442 Fourth Ave. San Diego, California 92101 Telephone: (619) 232-6022 MARK F. ADAMS ATTORNEY AT LAW California State Bar No. 97377 964 Fifth Ave., Suite 335 San Diego, California 92101 Telephone: (619) 239-4344 Attorneys for Defendant Christian Paul Rodarte

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) Case No. 08CR1560-JAH ) Plaintiff, ) JOINT MOTION TO CONTINUE ) MOTION HEARING ON MOTION ) FOR VIDEOTAPE DEPOSITION ) AND RELEASE OF MATERIAL ) WITNESS v. ) ) CHRISTIAN PAUL RODARTE, ) ) ) ) Defendant. ) ) ______________________________________) Defendant, CHRISTIAN PAUL RODARTE, by and through his counsel of record, Alex L. Landon and Mark F. Adams, the UNITED STATES, by and through its counsel of record, Nicole A. Jones, and Material Witness CGP (minor), by and through his counsel of record, Ciro Hernandez, hereby jointly move to continue the presently set motion hearing on motion for videotape deposition and release of material witness now scheduled for June 26, 2008 at 9:30 a.m. to July 1, 2008 at 9:30 a.m. before the Hon. Nita L. Stormes. The parties have conferred with the Court Clerk who has verified that the proposed new date is convenient for the Court. UNITED STATES OF AMERICA,

Case 3:08-cr-01560-JAH

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This joint motion is made and based upon the fact that all counsel are not available for the presently set motion hearing date.

Dated: June 10, 2008

/s/ Alex L. Landon______________ ALEX L. LANDON

Dated: June 10, 2008

/s/ Mark F. Adams______________ MARK F. ADAMS Attorneys for Defendant Christian Paul Rodarte

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/s/ Nicole A. Jones______________ KAREN P. HEWITT United States Attorney by: NICOLE A. JONES Assistant United States Attorney

/s/ Ciro Hernandez______________ CIRO HERNANDEZ Attorneys for Material Witness CGP (minor)

Case 3:08-cr-01560-JAH

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Filed 06/10/2008

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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 /S/ Mark F. Adams________ MARK F. ADAMS PROOF OF SERVICE I, Mark F. Adams, do hereby state: I am a citizen of the United States and a resident of the County of San Diego, State of California. I am over the age of eighteen years, and am not a party to the within action. My business address is 964 Fifth Avenue, Ste. 335, San Diego, California 92101. On this 10th day of June 2008, I served the within JOINT MOTION TO CONTINUE MOTION HEARING DATE in Case No. 08CR1560-JAH electronically through the CM/ECF system for the Southern District of California on the United States Attorney's Office, specifically AUSA Nicole A. Jones, a registered user of the CM/ECF system and on Material Witness Attorney Ciro Hernandez also a registered user of the CM/ECF system . I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct. EXECUTED this day, June 10, 2008, at San Diego, California.