Free Motion to Suppress Statements - District Court of California - California

Case 3:08-cr-00682-JLS

Document 75

Filed 05/30/2008

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GERALD T. McFADDEN (SBN 87446) Attorney at Law 2366 Front Street San Diego, CA 92101 (619) 338-0507 E-mail: [email protected] Attorney for Defendant JOSE PARADA-VELAZQUEZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. JANIS L. SAMMARTINO) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) JOSE PARADA-VELAZQUEZ, ) ) Defendant. ) ______________________________) TO: Crim. Case No. 08CR0682-07-JLS NOTICE OF MOTIONS AND MOTIONS TO SUPPRESS STATEMENTS, AND FOR LEAVE TO FILE FURTHER PRETRIAL MOTIONS AND FURTHER HEARING DATE NCD: June 13, 2008 at 1:30 p.m.

KAREN P. HEWITT, UNITED STATES ATTORNEY, STEVE MILLER, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on Friday, June 13, 2008, at 1:30 p.m., or as soon thereafter as

counsel may be heard, the defendant, JOSE PARADA-VELAZQUEZ, through his appointed counsel, Gerald T. McFadden, will bring the following motions. MOTIONS The defendant, JOSE PARADA-VELAZQUEZ, by and through his appointed counsel, Gerald T. McFadden, and pursuant to the provisions of Rules 12 and 16 of the Federal Rules of Criminal Procedure and the Fifth and Sixth Amendments to the United States' Constitution, hereby moves this Court: to suppress statements and, for leave to file further pretrial motions and a further hearing date. These motions are based upon the instant motions and notice of motions, the attached

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Case 3:08-cr-00682-JLS

Document 75

Filed 05/30/2008

Page 2 of 2

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statement of facts and points and authorities in support of these motions, and any and all matters that may come to the Court's attention prior to or at the time of the hearing of these motions. Respectfully submitted,

Dated: May 30, 2008

s/Gerald T. McFadden GERALD T. McFADDEN, Attorney for Defendant JOSE PARADA-VELAZQUEZ E-mail: [email protected]

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