Case 3:08-cr-01093-BEN
Document 7
Filed 05/28/2008
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SYLVIA BAIZ California Bar Number 124367 The Granger Building 964 Fifth Avenue, Suite 214 San Diego, California 92101 Telephone: (619) 544-1410 Facsimile: (619) 544-1473 Attorney for Defendant Gonzalez-Ramirez
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. ROGER T. BENITEZ) UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) ) Criminal No. 08-CR-1093-BEN Date: June 2, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; AND 2) DISMISS INDICTMENT; 3) LEAVE TO FILE FURTHER MOTIONS
11 Plaintiff, 12 v. 13 JUAN GONZALEZ-RAMIREZ, 14 Defendant. 15 16 TO: 17 18 19 20 21 22 23 24 25 26 27 28
KAREN HEWITT, UNITED STATES ATTORNEY, AND PAUL STARITA, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on June 2, 2008 at 2:00 p.m., or as soon thereafter as
counsel may be heard, the defendant, Juan Gonzalez-Ramirez by and through his counsel, Sylvia Baiz, will hereby move this Court for the above-entitled motions. // // // // // // // //
Case 3:08-cr-01093-BEN
Document 7
Filed 05/28/2008
Page 2 of 2
1 2 3 4 5 6 7 8 9 10 11 12 13 14 Dated: May 28, 2008 15 16 17 18 19 20 21 22 23 24 25 26 27 28
MOTIONS The defendant, Juan Gonzalez-Ramirez, by and through his attorney, Sylvia Baiz, and pursuant to Rules 12, 16, 24(a) of the Federal Rules of Criminal Procedure and Rules 404, 403, 609 of Federal Rules of Evidence any and all applicable local rules, hereby moves this Court to grant the following motions: 1) compel discovery; 2) dismiss the indictment; 3) leave to file further motions These motions are based upon 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 evidence brought before this Court before or during the hearing on this motion. Respectfully submitted,
/s/ Sylvia Baiz SYLVIA BAIZ Attorney for Defendant Gonzalez-Ramirez
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