Case 3:07-cr-03101-LAB 1 2 3 4 5 6 7 8 9 10 11 12 13 v. 14 JULIO MARTINEZ-HERNANDEZ, 15 Defendant. 16
Document 15
Filed 12/11/2007
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LINDA LOPEZ Florida Bar No. 0177301 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected] Attorneys for Mr. Julio Martinez-Hernandez
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE LARRY A. BURNS) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 07CR3101-LAB DATE: DECEMBER 17, 2007 TIME: 2:00 P.M. NOTICE OF MOTIONS AND MOTIONS TO: 1) DISMISS FOR GRAND JURY VIOLATION
____________________________________ 17 18 19 20 21 22 23 24 25 26 27 28 TO:
KAREN P. HEWITT, INTERIM UNITED STATES ATTORNEY, AND DALE BLAKENSHIP, 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, defendant, Julio Martinez-Hernandez, by and through his attorneys, Linda Lopez and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions.
07CR3101
Case 3:07-cr-03101-LAB 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: December 11, 2007
Document 15
Filed 12/11/2007
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MOTIONS Defendant, Julio Martinez-Hernandez, by and through his attorneys, Linda Lopez 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 for Grand Jury Violation.
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/ Linda Lopez LINDA LOPEZ Federal Defenders of San Diego, Inc. Attorneys for Mr. Julio Martinez-Hernandez [email protected]
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07CR3101