Free Motion to Continue - District Court of California - California

Case 3:08-cr-00631-BEN

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Filed 06/13/2008

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Charles L. Rees (State Bar No. 200682) Attorney at Law 424 F Street, Suite D San Diego, California 92101 Telephone: (619) 239-9300 Facsimile: (619) 702-5415 Attorney for Jose Alberto De Zabala

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) JOSE ALBERTO DE ZABALA, ) ) ) Defendant. ) ) ) Criminal No. 08CR631BEN JOINT MOTION TO CONTINUE SENTENCING HEARING

IT IS HEREBY REQUESTED by the parties in this case, defendant Jose Alberto De Zabala,
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by and through his counsel, CHARLES L. REES, and the United States Attorney's Office, by and through
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Assistant United States Attorney, David Leshner, that the sentencing hearing in the above-entitled case,
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scheduled for June 16, 2008, at 9:00 a.m., be continued until July 21, 2008, at 9:00 a.m. The parties further
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agree that the time between June 16, 2008, until July 21, 2008, is excludable under the Speedy Trial Act,
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until the acceptance of the plea agreement.
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A proposed order with respect to this joint motion is being e-mailed directly to the Court.
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Dated:

June 13, 2008

/s/ David Leshner DAVID LESHNER Assistant United States Attorney /s/ Charles L. Rees CHARLES L. REES Attorney for Mr. De Zabala

Dated:

June 13, 2008

08CR631BEN