Free Motion to Compel - District Court of California - California

Case 3:08-cr-00647-JM

Document 11

Filed 03/27/2008

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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 Ms. Sanchez

6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HONORABLE JEFFREY T. MILLER) 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 ALMA ANDREA SANCHEZ, 15 Defendant. 16 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that on April 11, 2008, at 11:00 a.m. or as soon thereafter as counsel may be heard, the defendant, Alma Andrea Sanchez, by and through her counsel, Bridget Kennedy and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // // TO: ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0647-JM DATE: TIME: April 11, 2008 11:00 a.m.

NOTICE OF MOTIONS AND MOTIONS: TO COMPEL DISCOVERY/PRESERVE EVIDENCE; (2) TO PRESERVE AND RE-WEIGH NARCOTIC EVIDENCE; (3) TO DISMISS THE INDICTMENT DUE TO MISINSTRUCTION OF THE GRAND JURY; AND (4) GRANT LEAVE TO FILE FURTHER MOTIONS (1)

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND AARON CLARK, ASSISTANT UNITED STATES ATTORNEY:

Case 3:08-cr-00647-JM

Document 11

Filed 03/27/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 27, 2008

MOTIONS The defendant, Alma Andrea Sanchez, by and through her 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) to compel discovery/preserve evidence; 2) to preserve and re-weigh narcotic evidence; 3) to suppress statements; 4) dismiss the Indictment due to misinstruction of the Grand Jury; and, 5) for leave to file further motions. 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 Ms. Sanchez

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08CR0647-JM