Free Motion for Discovery - District Court of California - California

Case 3:08-cr-01455-BEN

Document 38-3

Filed 06/16/2008

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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: June 30, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) (4) (5) (6) DISMISS INDICTMENT D U E T O MISINSTRUCTION OF THE GRAND JURY; PRESERVE EVIDENCE; COMPEL DISCOVERY; SEVER DEFENDANTS; SUPPRESS STATEMENTS; AND GRANT LEAVE TO FILE FURTHER MOTIONS

TO:

KAREN P. HEWIT, UNITED STATES ATTORNEY, AND REBECCA KANTER, ASSISTANT UNITED STATES ATTORNEY. PLEASE TAKE NOTICE that on June 30, 2008, at 2:00 p.m. or as soon thereafter as counsel

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may be heard, Defendant Arsen Motivosyan, by and through his counsel, Jodi Thorp will ask this Court to
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enter an order granting the following motions.
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MOTIONS
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Defendant Arsen Motivosyan, by and through his counsel, Jodi D. Thorp, Inc., moves this Court
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pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable
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Case 3:08-cr-01455-BEN

Document 38-3

Filed 06/16/2008

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statutes, case law, and local rules for an order to: (1) (2) (3) (4) (5) (6) Dismiss Indictment Due to Misinstruction of the Grand Jury; Preserve Evidence; Compel Discovery; Sever Defendants; Suppress Statements; and Grant Leave to File Further Motions.

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: June 16, 2008

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07CR3104-LAB

Case 3:08-cr-01455-BEN

Document 38-3

Filed 06/16/2008

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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 [email protected]
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Counsel for Mr. Motivosyan

UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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(HONORABLE ROGER T. BENITEZ)
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) ) Plaintiff, ) ) v. ) ) ARSEN MOTIVOSYAN ) ) ) Defendant. ) ___________________________________________)

UNITED STATES OF AMERICA,

CASE NO. 08CR1455-BEN DATE: June 30, 2008 TIME: 2:00 p.m. CERTIFICATE OF SERVICE

Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her
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information and belief, and that a copy of the foregoing document has been served this day upon:
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U S Attorney CR [email protected]

DATED:

June 16, 2008

/s/ Jodi D. Thorp JODI D. THORP Counsel for Mr. Motivosyan