Free Motion to Allow - District Court of California - California

Case 3:07-cr-03239-JM

Document 24

Filed 05/26/2008

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KAREN P. HEWITT United States Attorney NICOLE ACTON JONES TARA MCGRATH Assistant U.S. Attorneys California State Bar No. 231929, 254209 United States Courthouse 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-5684 Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT

9 SOUTHERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 13 14 15 COMES NOW the plaintiff, UNITED STATES OF AMERICA, by and 16 through its counsel, Karen P. Hewitt, United States Attorney, 17 and Nicole Acton Jones and Tara McGrath, Assistant United States 18 Attorneys, and requests the Court to permit the Government to 19 bring into the Courthouse, during the above-referenced trial 20 scheduled to begin on June 2, 2008 at 9:00 a.m., a firearm, to 21 wit: 22 machinegun, Serial Number 30 2923. 23 required triggerlock safety device at all times. 24 DATED: 25 26 27 28 \s\Nicole Acton Jones NICOLE ACTON JONES TARA MCGRATH Assistant U.S. Attorneys KAREN P. HEWITT United States Attorney May 26, 2008. Respectfully submitted, Said firearm will have the a Bulgaria, Model AKK (AK-47), 7.62 x 39 caliber v. LEONARDO SAN JUAN, JR., Defendant. ) ) ) ) ) ) ) ) ) Case No. 07CR3239-JM MOTION TO PERMIT GOVERNMENT TO BRING FIREARM INTO COURTHOUSE

Case 3:07-cr-03239-JM

Document 24

Filed 05/26/2008

Page 2 of 2

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) Case No. 07cr3239-JM

CERTIFICATE OF SERVICE

LEONARDO SAN JUAN, JR. Defendant.

IT IS HEREBY CERTIFIED THAT: 9 10 11 12 13 14 1) Joseph H. Low IV 15 16 17 none 18 19 20 21 Executed on May 26, 2008. 22 23 24 25 26 27 28 2 s/Nicole Acton Jones NICOLE ACTON JONES E-mail: [email protected] the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct. I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case: I am not a party to the above-entitled action. I have caused service of Motion to Permit Government to Bring Firearm into Courthouse on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. I, Nicole A. Jones, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893.