Free Motion to Suppress - District Court of California - California

Case 3:07-cr-03408-BEN

Document 13

Filed 03/10/2008

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JASON I. SER California State Bar No. 201816 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 Attorneys for Mr. Calderon-Quinonez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) ) Plaintiff, ) ) v. ) ) LUIS CALDERON-QUINONEZ, ) ) ) ) Defendant. ) ) ) ) _____________________________________ ) UNITED STATES OF AMERICA, TO: Case No.: 07cr3408-BEN Date: Time: March 24, 2008 2:00 p.m.

NOTICE OF MOTIONS AND MOTIONS TO: (1) SUPPRESS EVIDENCE OBTAINED AS A RESULT OF AN UNCONSTITUTIONAL VEHICLE STOP; (2) SUPPRESS THE FRUITS OF AN ILLEGAL ARREST; AND, (3) GRANT LEAVE TO FILE FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND CHRISTOPHER M. ALEXANDER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on March 24, 2008, at 2:00 p.m., or as soon thereafter as counsel

may be heard, the accused, Luis Calderon-Quinonez, by and through his attorneys, Jason I. Ser and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions outlined below.

Case 3:07-cr-03408-BEN

Document 13

Filed 03/10/2008

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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: March 10, 2008

MOTIONS Defendant, Mr. Calderon-Quinonez, by and through his attorneys, Jason I. Ser 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 to: (1) (2) (3) Suppress Evidence Obtained as a Result of an Unconstitutional Vehicle Stop; Suppress the Fruits of an Illegal Arrest; And, Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, and any and all other materials that may come to this Court's attention at or before the time of the hearing on these motions. Respectfully submitted,

JASON I. SER Federal Defenders of San Diego, Inc. Attorneys for Mr. Calderon-Quinonez

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07cr3408-BEN