Free Motion to Continue - District Court of California - California

Case 3:08-cr-02333-H

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1 LEILA W. MORGAN 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 3 San Diego, California 92101-5008 4 Facsimile: 5

California State Bar No. 232874 225 Broadway, Suite 900

Telephone: (619) 234-8467 Ext. 3737 (619) 687-2666 [email protected]

6 Attorneys for Mr. Andrade-Ocaranza 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE MARILYN L. HUFF) ) ) Plaintiff, ) ) v. ) ) JOSE ALBERTO ANDRADE-OCARANZA, ) ) Defendant. ) ) Case No. 08cr2333-H

11 UNITED STATES OF AMERICA, 12 13 14 15 16

JOINT MOTION TO CONTINUE MOTION HEARING

17 TO: 18 19

KAREN HEWITT, UNITED STATES ATTORNEY; CAROLINE HAN, ASSISTANT UNITED STATES ATTORNEY. Jose Alberto Andrade-Ocaranza, by and through his attorneys, Leila W. Morgan and Federal

20 Defenders of San Diego, counsel for Mr. Andrade, jointly moves with Assistant United States Attorney 21 Caroline P. Han, that the motion hearing currently set for September 2, 2008, at 2:00 p.m. be continued until 22 September 15, 2008, at 2:00 p.m. Mr. Andrade is currently in the custody of the U.S. Marshalls. The parties 23 also agree that time should be excluded under the speedy trial act, as there are still motions pending in the case 24 that are not resolved. Mr. Andrade currently has an appearance scheduled before Magistrate Judge William 25 McCurine on August 28, 2008, for a change of plea hearing. 26 // 27 // 28 //

//

Case 3:08-cr-02333-H

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For the foregoing reasons, the parties jointly request that the sentencing hearing be continued until

2 September 15, 2008 at 2:00 p.m. 3 4 Dated: August 27, 2008 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/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Mr. Andrade [email protected] /s/ Caroline P. Han CAROLINE P. HAN Assistant United States Attorney [email protected]

Dated: August 27, 2008

Case 3:08-cr-02333-H

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her

3 information and belief, and that a copy of the foregoing document has been served this day upon: 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

Caroline P. Han U S Attorneys Office Southern District of California Civil Division 880 Front Street Suite 6253 San Diego, CA 92101 (619)557-5662 Fax: (619)235-2757 Email: [email protected]

Dated: August 27, 2008

/s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Mr. Andrade [email protected]

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08cr2333-H