Free Motion to Dismiss - District Court of California - California

Case 3:08-cr-01081-BTM
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO: v. OMAR JAVIER LARA,

Document 16

Filed 05/23/2008

Page 1 of 2

NORMA A. AGUILAR Federal Defenders of San Diego, Inc. California State Bar No. 211088 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467/Fax: (619) 687-2666 E-Mail: [email protected] Attorney for Mr. Lara,

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE BARRY T. MOSKOWTIZ) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR1081-BTM DATE: MAY 27, 2008 TIME: 1:30 P.M. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) DISMISS FOR GRAND JURY VIOLATION; COMPEL DISCOVERY/PRESERVE EVIDENCE; GRANT LEAVE TO FILE FURTHER MOTIONS

Defendant.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHARLOTTE KAISER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on May 27, 2008 at 1:30 p.m., or as soon thereafter as counsel may

be heard, defendant, Omar Javier Lara, by and through his attorney, Norma A. Aguilar, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // // // // // 08CR1081-BTM

Case 3:08-cr-01081-BTM
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: May 23, 2008

Document 16

Filed 05/23/2008

Page 2 of 2

MOTIONS Defendant, Omar Javier Lara, by and through his attorney, Norma A. Aguilar and Federal Defenders of San Diego Inc., asks 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 to: (1) (2) (3) Dismiss for Grand Jury Violation; Compel Discovery/Preserve Evidence; Grant Leave to File Further Motions.

These motions are 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/ Norma A. Aguilar NORMA A. AGUILAR Attorney for Mr. Lara [email protected]

2

08CR1081-BTM