Free Motion to Exclude - District Court of California - California

Case 3:08-cr-00094-JLS

Document 27

Filed 09/12/2008

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ROBERT C. SCHLEIN SBN: 97876 ROBERT C. SCHLEIN AND ASSOCIATES 401 B STREET, SUITE 2209 SAN DIEGO, CALIF.92101-4245 (619) 235-9026 Fax: (619) 235-9057 Attorney for Ezequiel Manzo-Gaitan

5 6 7 8 9 10 11 12 13 14 15 16 TO: 17 18 19 20 21 22 23 24 25 26 27 This motion in limine is based upon the attached statement of facts and memorandum of 28
Notice of Motion In Limine 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Honorable Janis L. Sammartino) ) ) Plaintiff, ) ) ) v. ) ) EZEQUIEL MANZO-GAITAN ) a.k.a. Francisco Mejia-Anancleto, ) ) ) Defendant. ) ) ) ______________________________________) UNITED STATES OF AMERICA, Case No.: 08cr0094-JLS Date: September 26, 2008 Time: 2 p.m. SUPPLEMENTAL NOTICE OF MOTION IN LIMINE AND MOTION IN LIMINE TO: EXCLUDE DEFENDANT'S POST-ARREST STATEMENT TO THE GOVERNMENT REGARDING PRIOR ALIEN SMUGGLING ACTIVITY IN MEXICO

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND REBECCA S. KANTER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on September 26, 2008 at 2 p.m. or as soon thereafter as

counsel may be heard, the accused, Defendant Ezequiel Manzo-Gaitan, by and through his counsel, Robert C. Schlein of Robert Schlein and Associates, will hereby move this Court to grant the above entitled motions. MOTION The accused, Ezequiel Manzo-Gaitan, by and through his attorney, Robert C. Schlein hereby files the attached motion in limine of facts and law relating to this case. It is as follows: 1. Exclude Defendant's Post-Arrest Statements to the Government Regarding Prior Alien Smuggling Activity in Mexico.

Case 3:08-cr-00094-JLS

Document 27

Filed 09/12/2008

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points and authorities, the files and records in the above-captioned matter, and any and all other evidence brought before this Court before or during the hearing on these motions. Respectfully submitted,

4 5 Dated: September 11, 2008 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Notice of Motion In Limine 2

s/Robert C. Schlein Robert C. Schlein Robert Schlein and Associates Attorney for Ezequiel Manzo-Gaitan