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

Case 3:08-cr-00020-BTM

Document 13

Filed 01/22/2008

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LEE PLUMMER California State Bar Number 77783 Attorney at Law 4045 Bonita Rd. #202 Bonita, Ca. 91902 Telephone: (619) 267-1710 Attorney for Defendant Juan Rafael Zafra Gomez

UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE BARRY TED MOSKOWITZ) 10 11 12 13 14 15 16 17 18 TO: 19 PLEASE TAKE NOTICE that on Friday, February 1, 2008, at 1:30 20 P.M., or as soon thereafter as counsel may be heard, the defendant, 21 Juan Rafael Zafra Gomez, by and through counsel, LEE PLUMMER will ask 22 this Court to issue an order granting the motions listed below. 23 // 24 // 25 // 26 27 28 -1KAREN HEWITT, UNITED STATES ATTORNEY: v. JUAN RAFAEL ZAFRA GOMEZ, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08-CR-0020-BTM Date: February 1, 2008 Time: 1:30 P.M. NOTICE OF MOTIONS AND MOTIONS TO: 1) SUPPRESS STATEMENTS; AND 2) LEAVE TO FILE FURTHER MOTIONS

Case 3:08-cr-00020-BTM

Document 13

Filed 01/22/2008

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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 Dated: January 22, 2008

MOTIONS The defendant, Juan Rafael Zafra Gomez, by and through counsel, LEE PLUMMER, asks this Court pursuant to the Fifth and Sixth Amendments, to the United States Constitution, Fed. R. Crim. P. 12, 16 and 26, and all other applicable statutes and local rules for an order to: 1) Suppress Statements; and 2) 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, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions.

Respectfully submitted,

/s/ Lee Plummer Attorney for Defendant

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