Free Motion to Dismiss - District Court of California - California

Case 3:07-cr-00625-MAG

Document 22

Filed 01/24/2008

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BARRY J. PORTMAN Federal Public Defender ERIC MATTHEW HAIRSTON Assistant Federal Public Defender 450 Golden Gate Avenue San Francisco, CA 94102 Telephone: (415) 436-7700 Counsel for Defendant DANIELS

IN THE UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 On January 24, 2008, the government moved to dismiss the information filed in the above16 referenced case without prejudice. This matter was set for a bench trial on January 25, 2008, and 17 jeopardy would therefore have attached on that date. In light of the proximity of trial and the 18 substantial preparation undertaken in furtherance thereof, Mr. Clifford Daniels hereby moves for a 19 dismissal of the information against him with prejudice or, in the alternative, for trial to proceed 20 as scheduled on January 25, 2008 at 9:00 a.m. 21 Dated: January 24, 2008 22 Respectfully submitted, 23 24 25 26 BARRY J. PORTMAN Federal Public Defender /S/ ERIC MATTHEW HAIRSTON Assistant Federal Public Defender v. CLIFFORD DANIELS, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) No. CR 07-0625 MAG MOTION TO DISMISS WITH PREJUDICE