Free Motion for Joinder - District Court of California - California

Case 3:08-cr-01455-BEN

Document 65

Filed 08/19/2008

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JODI D. THORP California Bar No. 223663 2 427 "C" Street Suite 300 San Diego, California 92101 3 Telephone: (619) 233-3169 ext. 14 [email protected]
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Counsel for Mr. Motivosyan

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) UNITED STATES OF AMERICA, Plaintiff, v. ARSEN MOTIVOSYAN, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) U.S.D.C. No. 08CR1455-BEN Date: September 2, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) JOIN IN MOTIONS FILED ON BEHALF OF CODEFENDANT ARA AVETYANTS.

TO:
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KAREN P. HEWIT, UNITED STATES ATTORNEY, AND REBECCA KANTER, ASSISTANT UNITED STATES ATTORNEY. PLEASE TAKE NOTICE that on September 2, 2008, at 2:00 p.m. or as soon thereafter as

counsel may be heard, Defendant Arsen Motivosyan, by and through his counsel, Jodi Thorp will ask this Court to enter an order allowing him to join in the motion to suppress evidence and statements due to an illegal stop.

Case 3:08-cr-01455-BEN

Document 65

Filed 08/19/2008

Page 2 of 2

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MOTIONS Defendant Arsen Motivosyan, by and through his counsel, Jodi D. Thorp, Inc., moves this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order allowing him to join in codefendant Ara Avetyants motions to suppress evidence based on his challenging of the illegal stop in this case. Mr. Motivsoyan further requests this Court suppress any statements the government alleges Mr. Motivosyan made during the stop. This motion is based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. Respectfully submitted, s/ Jodi Thorp JODI THORP Counsel for Mr. Motivosyan

Dated: August 19, 2008

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08CR1455-BEN