Free Motion to Dismiss Indictment - District Court of California - California

Case 3:08-cr-00794-L
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Document 10

Filed 04/07/2008

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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] Attorneys for Ms.. Lacey Desiree Espinoza

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) UNITED STATES OF AMERICA, Plaintiff, v. LACEY DESIREE ESPINOZA, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0794-MJL DATE: APRIL 21, 2008 TIME: 2:00 P.M. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) (4) DISMISS THE INDICTMENT FOR GRAND JURY VIOLATION; SUPPRESS STATEMENTS; COMPEL DISCOVERY/PRESERVE EVIDENCE; AND GRANT LEAVE TO FILE FURTHER MOTIONS

TO:

KAREN HEWITT, UNITED STATES ATTORNEY, AND DALE BLANKENSHIP, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on April 21, 2008 at 2:00 p.m., or as soon thereafter as

counsel may be heard, defendant, Lacey Desiree Espinoza, by and through her attorneys, Norma A. Aguilar and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions.

08CR0794-MJL

Case 3:08-cr-00794-L
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Document 10

Filed 04/07/2008

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MOTIONS Defendant, Lacey Desiree Espinoza, by and through her 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) (4) Dismiss the Indictment for Grand Jury Violation; Suppress Statements; Compel Discovery/Preserve Evidence; and Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached
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statement of facts and memorandum of points and authorities, the files and records in the above10

captioned matter, and any and all other materials that may come to this Court's attention prior to or
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during the hearing of these motions.
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Respectfully submitted,
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Dated: April 7, 2008
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/s/ Norma A. Aguilar NORMA A. AGUILAR Attorney for Ms. Espinoza [email protected]

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