Free Motion to Continue - District Court of California - California

Case 3:08-cr-01636-BEN

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Filed 06/25/2008

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1 DAVID J. ZUGMAN California Bar No. 190818 2 964 Fifth Avenue, Suite 300 San Diego, California 92101-5008 3 Telephone: (619) 699-5931 Facsimile: (619) 699-5932 4 [email protected] 5 Attorney for Octavio Moreno Reyna 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) Criminal No. 08CR1636-BEN ) Plaintiff, ) Date: June 30, 2008 ) Time: 2:00 p.m. v. ) ) OCTAVIO MORENO REYNA, ) NOTICE OF JOINT MOTION TO CONTINUE ) MOTION HEARING Defendant. ) ) TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, and JEFFREY D. MOORE, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that Defendant, Octavio Moreno Reyna, by and 18 through his Counsel, David J. Zugman, files the instant joint motion to 19 continue the motion hearing from June 30, 2008, at 2:00 p.m. to August 20 11, 2008, at 2:00 p.m.. 21 Respectfully Submitted, 22 23 Date: June 25, 2008 24 25 26 27 28 S/David J. Zugman David J. Zugman Attorney for Mr. Reyna

11 UNITED STATES OF AMERICA, 12 13 14 15 16 17

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Case 3:08-cr-01636-BEN

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Filed 06/25/2008

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PROOF OF SERVICE I, the undersigned, declare that:

1. I am over eighteen (18) years of age; am a resident of the County of San Diego, State of California; and my business address is 964 4 Fifth Avenue, Suite 300, San Diego, California, 92101-5008. 5 2. I am effecting service of JOINT MOTION TO CONTINUE THE MOTION HEARING on the following parties by electronically filing the foregoing 6 with the Clerk of the District Court using its ECF System, which electronically notifies them: 7 Jeffrey Moore, Assistant U.S. Attorney 8 Office of the U.S. Attorney 880 Front Street 9 San Diego, CA 92101 10 3. I hereby certify that I have mailed the foregoing, by United States Postal Service to the following non-EFC participants in this case: 11 1. N/A 12 to the last known address, at which place there is delivery service of 13 mail from the United States Postal Service. 14 15 Executed on June 25, 2008. 16 17 S/David Zugman DAVID J. ZUGMAN 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury that the foregoing is true and correct.

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Case 3:08-cr-01636-BEN

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1 DAVID J. ZUGMAN California State Bar Number 190818 2 964 Fifth Avenue, Suite 300 San Diego, California 92101 3 Telephone: (619) 699-5931 Facsimile: (619) 699-5932 4 [email protected] 5 Attorney for Octavio Moreno Reyna 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR1636-BEN Date: June 30, 2008 Time: 2:00 p.m. JOINT MOTION TO CONTINUE THE MOTION HEARING

11 UNITED STATES OF AMERICA, 12 13 v. 14 OCTAVIO MORENO REYNA, 15 16 Defendant. Plaintiff,

THE PARTIES STIPULATE to continue Mr. Reyna's motion hearing from 17 June 30, 2008, at 2:00 p.m. to August 11, 2008, at 2:00 p.m.. 18 the first continuance request for the motion hearing. 19 anticipate arriving at plea agreement which will obviate the need for 20 the motion hearing. 21 is why the agreement has yet to be finalized. 22 The new date and time have been cleared with this Court's clerk. 23 IT IS SO STIPULATED: 24 Dated: June 25, 2008 25 26 Dated: June 25, 2008 27 28 08CR1636-BEN S/Jeffrey Moore JEFFREY MOORE ASSISTANT U.S. ATTORNEY S/David Zugman DAVID ZUGMAN ATTORNEY FOR MR. REYNA Mr. Reyna is in custody. Further, the parties have matters to resolve which The parties This is