Free Motion to Continue - District Court of California - California

Case 3:07-cr-03106-BEN

Document 18

Filed 12/06/2007

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1 LEILA W. MORGAN

California State Bar No. 232874
2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, California 92101-5008 Telephone: (619) 234-8467 Ext. 3737 4 Facsimile: (619) 687-2666 [email protected] 5 6 Attorneys for Ms. Vasquez 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3106-BEN

11 UNITED STATES OF AMERICA, 12 13 v. 14 MARIA VASQUEZ, 15 16 17 TO: 18 19 Defendant. Plaintiff,

JOINT MOTION TO CONTINUE MOTION HEARING

KAREN HEWITT, UNITED STATES ATTORNEY; MICHELLE PETIT, ASSISTANT UNITED STATES ATTORNEY. Maria Vasquez, by and through her attorneys, Leila W. Morgan and Federal Defenders of San Diego,

20 counsel for Ms. Vasquez jointly moves with Assistant United States Attorney Michele Petit, that the motion 21 hearing currently set for December 10, 2007, at 9:00 a.m. be continued until January 7, 2008, at 2:00 p.m. 22 The parties are attempting to resolve the case and believe that this continuance will allow them to do so. 23 Further, several pieces of discovery have recently been received by defense counsel and Ms. Vasquez requests 24 additional time to discuss this discovery with counsel. Ms. Vasquez is currently released on bond, a signed 25 acknowledge of her next court date is attached to this motion. 26 // 27 // 28

Case 3:07-cr-03106-BEN

Document 18

Filed 12/06/2007

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For the foregoing reasons, the parties jointly request that the motion hearing be continued until

2 January 7, 2008, at 2:00 p.m. 3 4 Dated: December 6, 2007 5 6 7 Dated: December 6, 2007 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3106-BEN /s/ Michelle Petit MICHELLE PETIT Assistant United States Attorney [email protected] /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]

Case 3:07-cr-03106-BEN

Document 18

Filed 12/06/2007

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her

3 information and belief, and that a copy of the foregoing document has been served this day upon: 4 Michelle Petit U S Attorneys Office Southern District of California 5 Civil Division 880 Front Street 6 Suite 6253 San Diego, CA 92101 7 (619)557-5662 Fax: (619)235-2757 8 Email: [email protected] 9 10 Dated: December 6, 2007 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 07cr3106-BEN /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]