Free Motion to Suppress Evidence - District Court of California - California

Case 3:07-cr-03106-BEN

Document 24

Filed 02/21/2008

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LEILA W. MORGAN California State Bar No. 232874 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467/Fax: (619) 687-2666 E-Mail: [email protected] Attorneys for Ms. Vasquez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) UNITED STATES OF AMERICA, Plaintiff, v. MARIA VASQUEZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3106-BEN DATE: Marcy 3, 2008 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS: (1) (2) (3) TO SUPPRESS EVIDENCE; TO SUPPRESS STATEMENTS; TO DISMISS THE INDICTMENT DUE TO MISINSTRUCTION OF THE GRAND JURY.

TO: 19 20

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND MICHELLE PETIT, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on March 3, 2008, at 2:00 p.m., or as soon thereafter as

21 counsel may be heard, the defendant, Maria Vasquez, by and through her counsel, Leila W. Morgan, 22 and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following 23 motions. 24 MOTIONS 25 The defendant, Maria Vasquez, by and through his attorneys, Leila W. Morgan, and Federal 26 Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of 27 Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this 28

Case 3:07-cr-03106-BEN

Document 24

Filed 02/21/2008

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Court for an order to: 1) 2) 3) To Suppress Evidence; To Suppress Statements; To Dismiss the Indictment Due to Misinstruction of the Grand Jury.

These motions are based upon the instant motions and notice of motions, the attached 5 statement of facts and memorandum of points and authorities, and all other materials that may come 6 to this Court's attention at the time of the hearing on these motions. 7 Respectfully submitted, 8 9 DATED: February 21, 2008 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07CR3106-BEN /s/ Leila W. Morgan LEILA W. MORGAN Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]