Free Motion to Continue - District Court of California - California

Case 3:08-cr-00068-JAH

Document 10

Filed 01/22/2008

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1 GEOFFREY C. MORRISON
(California State Bar No. 172059)

2 Geoffrey C. Morrison, Attorney at Law 3 San Diego, California 92101 4 Telephone: (619) 277-8822
Facsimile: (619) 233-4145 Attorney for Defendant 185 F Street, Ste. 100

5 6 CLEMENTE MOISES PULIDO-JAUREGUI 7 8 9 10 11 UNITED STATES OF AMERICA, 12 13
vs. Plaintiff, ) ) ) ) ) ) ) ) ) ) CRIM. CASE NO. 08-CR-00068-JAH STIPULATION FOR CONTINUANCE & ORDER THEREON Disposition Date: January 24, 2008 Time: 09:30 a.m. Dept. Mag. Judge Papas UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

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VICENTE CAMERENA-GARCIA, Defendant.

COME NOW the parties to this action, Plaintiff UNITED STATES OF AMERICA, by and

20 through United States Attorney for the Southern District of California Karen P. Hewitt and Assistant 21 United States Attorney Jeff Moore, and Defendant VICENTE CAMARENA-GARCIA (hereinafter 22 "Mr. Camarena"), by and through his attorney of record, Geoffrey C. Morrison, and respectfully 23
stipulate and agree that the disposition date in this matter, which is currently scheduled for January 24,

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2008, at 9:30 a.m., be continued until February 12, 2008, at 9:30 a.m. This Stipulation is made on the

26 following grounds: 27 28
1. Counsel for Mr. Camarena was just retained in this matter and, concurrently with the filing of this stipulation, is filing a Motion for Substitution of Counsel and Order Thereon; 08-CR-00068-JAH

Case 3:08-cr-00068-JAH

Document 10

Filed 01/22/2008

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2. That Counsel for Mr. Camerena has discussed the need for this continuance with AUSA Jeff Moore. Mr. Moore graciously agreed not to oppose Counsel's request.. 3. Mr. Camerena is in custody. The defendant remains detained, and the defendant will file an acknowledgement of the new date with this Court. IT IS SO STIPULATED AND AGREED.

9 Date: January 21, 2008 10 11 12 13 Date: January 21, 2008 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

By:_______/s Jeff Moore__________ Assistant United States Attorney Jeff Moore, attorney for the Plaintiff

By:______/s Geoffrey C. Morrison______ Geoffrey C. Morrison, attorney for the Defendant, Vicente Camerena-Garcia

08-CR-00068-JAH