May 9, 2013
UNITED STATES OF AMERICA, Plaintiff,
ADRIAN REYNOSO, Defendant,
BENJAMIN B. WAGNER, United States Attorney, JASON HITT, Assistant U.S. Attorney. Sacramento, California.
GOVERNMENT'S MOTION TO DISMISS THE INDICTMENT AND [PROPOSED] ORDER
[FED. R. CRIM. P. 48(a)]
WILLIAM B. SHUBB, District Judge.
The United States of America, by and through its attorney of record, Assistant United States Attorney Jason Hitt, hereby moves for an order dismissing the Indictment against defendant Adrian REYNOSO pursuant to Federal Rule of Criminal Procedure 48(a). This motion is made in the interests of justice. After careful review of evidentiary issues raised by the defense, including a possible legal defense to the charges, and consideration of the defendant's exemplary conduct during six years on pretrial release, including keeping gainful employment and caring for his longtime girlfriend who has been very ill, the undersigned respectfully requests that the Court enter an Order dismissing the pending Indictment against the defendant in the interests of justice pursuant to Rule 48(a).
For the reasons set forth in the motion to dismiss filed by the United States, IT IS HEREBY ORDERED that:
The Indictment against defendant Adrian REYNOSO is hereby DISMISSED pursuant to Federal Rule of Criminal Procedure 48(a).