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

Case 3:08-cr-01969-JM

Document 30

Filed 07/14/2008

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1 JASON I. SER

California State Bar No. 201816
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

225 Broadway, Suite 900
3 San Diego, California 92101-5008

Telephone: (619) 234-8467
4 [email protected] 5 Attorneys for Mr. Smith 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JEFFREY T. MILLER) ) ) ) ) ) ) ) ) ) ) Case No. 08cr1969-JM Date: July 25, 2008 Time: 11:00 a.m. MOTION FOR ORDER TO SHORTEN TIME

11 UNITED STATES OF AMERICA, 12 13 v. 14 MANLEY SMITH (2), 15 16

Plaintiff,

Defendant. TO:

17 18

KAREN HEWITT, UNITED STATES ATTORNEY; AND MARK CONOVER, ASSISTANT UNITED STATES ATTORNEY: The above-named defendant, by and through counsel, moves this Court for an order shortening time

19 to file his MOTIONS TO: 20 21 22 23

(1)PRESERVE AND INSPECT EVIDENCE; (2)COMPEL DISCOVERY; (3)COMPEL NOTICE PURSUANT TO FED. R. CRIM. P. 12(b)(4)(B); AND, (4)GRANT LEAVE TO FILE FURTHER MOTIONS,

24 to eleven (11) days, to be heard Friday, July 25, 2008 at 11:00 a.m., or as soon thereafter as counsel may be 25 heard, for the following reasons: 26 27 28

Case 3:08-cr-01969-JM

Document 30

Filed 07/14/2008

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1

Defense counsel was out of the district for two and a half weeks on vacation and did not return until

2 July 12, 2008. 3 4

Respectfully submitted, DATED: July 14, 2008 /s/ Jason I. Ser JASON I. SER Federal Defenders of San Diego, Inc. Attorneys for Mr. Smith E-mail: [email protected]

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2

Case 3:08-cr-01969-JM

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) UNITED STATES OF AMERICA, ) ) Plaintiff, ) v. ) ) MANLEY SMITH (2), ) ) Defendant. ) _______________________________________)

Case No. 08CR1969-JM

CERTIFICATE OF SERVICE

Counsel for Defendant certifies that the foregoing pleading, is true and accurate to the best of his information and belief, and that a copy of the foregoing Defendant's Motion to Shorten Time has been electronically served this day upon: W. Mark Conover Assistant U.S. Attorney 880 Front Street San Diego, CA 92101

Dated: July 14, 2008

/s/ Jason I. Ser JASON I. SER Federal Defenders 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467 (tel) (619) 687-2666 (fax) [email protected]