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


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Date: March 3, 2008
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State: California
Category: District Court of California
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Case 3:07-cr-03281-H

Document 19

Filed 03/03/2008

Page 1 of 2

1 ROBERT H. REXRODE, III California State Bar No. 230024 2 427 C Street, Suite 300 San Diego, California 92101 3 Telephone: (619) 233-3169, Ext. 13 Facsimile: (619) 684-3553 4 [email protected] 5 Attorney for Mr. Javier Soto-Castro 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE MARILYN L. HUFF) 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 JAVIER SOTO-CASTRO, 14 Defendant. 15 16 17 TO: 18 19 KAREN P. HEWITT, UNITED STATES ATTORNEY, AND ANDREW SCHOPLER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on March 17, 2008, at 2:00 p.m., or as soon thereafter ) ) ) ) ) ) ) ) ) ) ) CASE NO. DATE: TIME: 07cr3281-H March 17, 2008 2:00 p.m.

NOTICE OF MOTIONS: (1) (2) TO COMPEL DISCOVERY; AND, FOR LEAVE TO FILE FURTHER MOTIONS. ________________________________

20 as counsel may be heard, the defendant, Javier Soto-Castro, by and through his counsel, 21 Robert Rexrode, will ask this Court to enter an order granting the following motions. 22 23 MOTIONS The defendant, Javier Soto-Castro, by and through his attorney, Robert Rexrode,

24 pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all 25 other applicable statutes, case law and local rules, hereby moves this Court for an order: 26 27 28 // 1) to suppress statements; 2) to preserve and view evidence; and, 3) for leave to file further motions.

Case 3:07-cr-03281-H

Document 19

Filed 03/03/2008

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1

These motions are based upon the instant motions and notice of motions, the attached

2 statement of facts and memorandum of points and authorities, and all other materials that 3 may come to this Court's attention at the time of the hearing on these motion. 4 5 6 7 Dated: March 3, 2008 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3281 /s/ Robert H. Rexrode ROBERT H. REXRODE, III Attorney for Mr. Soto-Castro [email protected] Respectfully submitted,