Case 3:07-cr-03107-L
Document 9
Filed 11/29/2007
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KASHA K. POLLREISZ California State Bar No. 204148 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone: (619) 234-8467 Facsimile: (619) 687-2666 [email protected] Attorneys for Mr. Robles-Castro
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3107-MJL DATE: TIME: December 17, 2007 2:00 p.m.
12 Plaintiff, 13 v. 14 MIGUEL ROBLES-CASTRO, 15 Defendant. 16 17 18 19 20 21 TO: 22 23 24 25 26 27 28
NOTICE OF MOTIONS AND MOTIONS: (1) TO COMPEL DISCOVERY/PRESERVE EVIDENCE; (2) TO PRESERVE AND RE-WEIGH NARCOTIC EVIDENCE (3) TO DISMISS THE INDICTMENT DUE TO MISINSTRUCTION OF THE GRAND JURY; AND (4) GRANT LEAVE TO FILE FURTHER MOTIONS. __________________________________
KAREN P. HEWITT, ACTING UNITED STATES ATTORNEY, AND STEWART YOUNG, ASSISTANT UNITED STATES ATTORNEY:
PLEASE TAKE NOTICE that on December 17, 2007, at 2:00 p.m. or as soon thereafter as counsel may be heard, the defendant, Miguel Robles-Castro, by and through his counsel, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // //
Case 3:07-cr-03107-L
Document 9
Filed 11/29/2007
Page 2 of 2
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MOTIONS The defendant, Miguel Robles-Castro, by and through his attorneys, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 1) to compel discovery/preserve evidence; 2) to preserve and re-weigh narcotic evidence; 3) dismiss the Indictment due to misinstruction of the Grand Jury; and, 4) for leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached statement of
8 facts and memorandum of points and authorities, and all other materials that may come to this Court's 9 attention at the time of the hearing on these motions. 10 11 Respectfully submitted, 12 /s/ Kasha K. Pollreisz 13 Dated: November 29, 2007 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07CR3107-MJL KASHA K. POLLREISZ Federal Defenders of San Diego, Inc. Attorneys for Mr. Robles-Castro [email protected]