Free Motion to Dismiss Indictment - District Court of California - California

Case 3:07-cr-03158-JLS
1 2 3 4 5

Document 17

Filed 05/15/2008

Page 1 of 2

LEILA W. MORGAN California Bar No. 232874 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected] Attorneys for Ms. Buenrostro-Villareal

6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HONORABLE JANIS L. SAMMARTINO) 11 UNITED STATES OF AMERICA, 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that on May 16, 2008, at 1:30 p.m., or as soon thereafter as counsel may be heard, defendant, Luz Maria Buenrostro-Villaruel, by and through her attorneys, Leila W. Morgan and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. /// /// /// /// 07cr3158-JLS TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, AND ANDREW SCHOPLER, ASSISTANT UNITED STATES ATTORNEY: ) ) Plaintiff, ) ) ) v. ) ) LUZ MARIA BUENROSTRO-VILLARUEL, ) ) ) Defendant. ) ) ) ) ____________________________________ CASE NO: 07CR3158-JLS DATE: May 15, 2008 TIME: 1:30 p.m.

NOTICE OF MOTIONS AND MOTIONS TO: 1) DISMISS INDICTMENT DUE TO INVALID DEPORTATION.

Case 3:07-cr-03158-JLS
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 26 27 28 Dated: May 15, 2008

Document 17

Filed 05/15/2008

Page 2 of 2

MOTIONS Defendant, Luz Maria Buenrostro-Villaruel, by and through her attorneys, Leila W. Morgan and Federal Defenders of San Diego, Inc., asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order to: (1) Dismiss Indictment Due to Invalid Deportation. 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/ Leila W. Morgan LEILA W. MORGAN Federal Defenders of San Diego, Inc. Attorneys for Ms. Buenrostro-Villaruel [email protected]

1

07cr3158-JLS