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


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Date: April 15, 2008
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State: California
Category: District Court of California
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Case 3:08-cr-00726-DMS

Document 14

Filed 04/15/2008

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BRIDGET KENNEDY California State Bar No. 253416 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone: (619) 234-8467, ext. 3740 Fax: (619) 687-2666 [email protected] Attorneys for Mr. Garcia

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) UNITED STATES OF AMERICA, Plaintiff, v. JESUS DAVID GARCIA, Defendant. ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0726-DMS DATE: TIME: April 25, 2008 11:00 a.m.

NOTICE OF MOTIONS AND MOTIONS: (1) TO DISMISS THE INDICTMENT DUE TO MISINSTRUCTION OF THE GRAND JURY

TO:

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHRISTINA McCALL, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on April 25, 2008, at 11:00 a.m. or as soon thereafter as

counsel may be heard, the defendant, Jesus David Garcia, by and through his counsel, Bridget Kennedy and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // // // // // //

Case 3:08-cr-00726-DMS

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MOTIONS The defendant, Jesus David Garcia, by and through his attorneys, Bridget Kennedy and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 1) dismiss the Indictment due to misinstruction of the Grand Jury. These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, and all other materials that may come to this Court's attention at the time of the hearing on these motions. Respectfully submitted, s/ Bridget Kennedy BRIDGET KENNEDY Federal Defenders of San Diego, Inc. Attorneys for Mr. Garcia

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08CR0726-DMS