Free Motion to Compel - District Court of California - California

Case 3:08-cr-00801-WQH

Document 17

Filed 04/09/2008

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1 CAREY D. GORDEN California State Bar No. 236261 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, CA 92101-5030 (619) 234-8467/Fax: (619) 687-2666 4 E-Mail: [email protected] 5 Attorneys for Mr. Juan Antonio Ramirez-Lozano 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0801-WQH DATE: TIME: April 28, 2008 2:00 p.m.

11 UNITED STATES OF AMERICA, 12 13 v. 14 JUAN ANTONIO RAMIREZ-LOZANO, 15 16 17 18 19 20 TO: 21 22 Defendant. Plaintiff,

NOTICE OF MOTIONS AND MOTIONS: (1) (2) (3) (4) TO COMPEL DISCOVERY; TO DISMISS THE INDICTMENT DUE TO IMPROPER GRAND JURY INSTRUCTION; TO SUPPRESS STATEMENTS; AND TO GRANT LEAVE TO FILE FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND LUELLA CALDITO, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on April 28, 2008, at 2:00 p.m., or as soon thereafter as

23 counsel may be heard, the defendant, Juan Antonio Ramirez-Lozano, by and through his counsel, 24 Carey D. Gorden, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order 25 granting the following motions. 26 / / / 27 / / / 28 / / /

Case 3:08-cr-00801-WQH

Document 17

Filed 04/09/2008

Page 2 of 2

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MOTIONS The defendant, Juan Antonio Ramirez-Lozano, by and through his attorneys,

3 Carey D. Gorden, and Federal Defenders of San Diego, Inc., pursuant to the United States 4 Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and 5 local rules, hereby moves this Court for an order to: 6 7 8 9 These motions are based upon the instant motions and notice of motions, the attached 1) 2) 3) 4) Compel discovery; Dismiss the indictment due to misinstruction of the grand jury; Suppress statements; and Grant leave to file further motions.

10 statement of facts and memorandum of points and authorities, and all other materials that may come 11 to this Court's attention at the time of the hearing on these motions. 12 13 14 DATED: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08CR0801-WQH April 9, 2008 /s/ Carey D. Gorden CAREY D. GORDEN Federal Defenders of San Diego, Inc. Attorneys for Mr. Ramirez-Lozano Respectfully submitted,