Free Motion to Continue - District Court of California - California

Case 3:08-cr-00676-W

Document 19

Filed 06/19/2008

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Francisco León Francisco León, P.C. 177 N. Church Ave. Suite 911 Tucson, Arizona 85701-1120 Az. Bar: 006578 Pima County Bar: 33924 520-620-1800 FAX 520-624-5586 [email protected] UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS J. WHELAN)
) ) ) ) ) ) ) ) ) ) Case No.: 08-CR--00676-001-TJW DEFENDANT'S MOTION TO CONTINUE SENTENCING FOR 30 DAYS

UNITED STATES OF AMERICA, Plaintiff, vs. ANGEL VAZQUEZ-TOLEDO, Defendant

Defendant Angel Vazquez-Toledo, by and through his counsel undersigned, moves the Court to issue its order continuing the sentencing in the above-captioned matter for a period of 30 days or as soon thereafter as is convenient for the Court and parties. This motion is made on the grounds that the Defendant was unable to establish his qualification for "safety valve" treatment until June 18, 2008, when he was made available for interview by the United States Attorney's Office. DEFENDANT'S MOTION TO CONTINUE SENTENCING FOR 30 DAYS; Page 1

Case 3:08-cr-00676-W

Document 19

Filed 06/19/2008

Page 2 of 2

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AUSA George Manahan, the Assistant United States Attorney handling this matter, has stated to undersigned counsel that he will notify the Court and Probation Office that Mr. Vazquez-Toledo has fulfilled the requirements to qualify him for "safety valve" treatment. Undersigned counsel, however, requires additional time to prepare and submit a Sentencing Memorandum prior to sentencing which includes the "safety valve" consideration. Undersigned counsel is authorized to state that AUSA George Manahan takes no position with regard to this motion or any order based thereon. For all the forgoing reasons, the sentencing in this matter should be continued from June 23, 2008 for a period of 30 days or as soon thereafter as is convenient for the Court and parties. Submitted this 19th day of June, 2008.
FRANCISCO LEÓN, P.C. /s/Francisco León Francisco Leon [email protected]
Copies of the forgoing mailed/electronically delivered this 19th day of June, 2008 to the following: George Manahan Assistant United States Attorney Carolyn M. Casutt Probation Officer Andrew Nietor Local Counsel for Defendant Angel Vazquez-Toledo

DEFENDANT'S MOTION TO CONTINUE SENTENCING FOR 30 DAYS; Page 2