Free Motion for Bond - District Court of California - California

Case 3:07-mj-02999-CAB

Document 4

Filed 01/23/2008

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DANIEL CASILLAS, ESQ., SBN 110298 Attorney at Law 101 West Broadway, Suite 1950 San Diego, California 92101 Tel: (619) 237-3777 Fax: (619) 238-9914 Email: [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE CATHY ANN BENCIVENGO) UNITED STATES OF AMERICA, Plaintiff, vs. NOTICE OF MOTION AND MOTION FOR DEFENDANT'S PRETRIAL RELEASE ON BAIL PURSUANT TO 18 U.S.C.§3141 ET. SEQ. Defendant. Criminal Case No. 07MJ2999-CAB DATE: January 24, 2008 TIME: 9:30 a.m.

JOSE ESTRADA,

PLEASE TAKE NOTICE that on the above date and time, or as soon thereafter as counsel may be heard, defendant, JOSE ESTRADA, by and through his counsel, Daniel Casillas, will respectfully move this Court to issue an order granting reasonable bail in this matter, pursuant to the Bail Reform Act of 1984, Title 18, United States Code, §§ 3141, et seq. This motion is based upon the instant Motion and Notice of Motions, the attached statement of facts, the memorandum of points and authorities, and the files and records in the above-captioned case, and any and all evidence which may come to this Court's attention prior to or during the hearing of these motions. Dated: January 23, 2008 Respectfully submitted, s/DANIEL CASILLAS DANIEL CASILLAS Attorney for Defendant JOSE ESTRADA
07MJ2999-CAB