IN THE

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA )

)

) NO.

v. ) Judge Milton I. Shadur

)

)

)

DEFENDANT LUIS SANCHEZ' MOTION FOR JUDGMENT OF ACQUITTAL

Defendant, LUIS SANCHEZ, by the Federal Defender Program and its attorneys SERGIO F. RODRIGUEZ and LUIS M. GALVAN, respectfully requests that this Court, pursuant to Rule 29(c) of the Federal Rules of Criminal Procedure, enter a judgment of acquittal in this case on Counts 1, 2, and 3 based upon the insufficiency of the evidence introduced by the government. Defendant submits that no rational trier of fact could find the government's evidence supported a finding of guilt beyond a reasonable doubt.

In support of this motion, defendant submits the attached memorandum. ⁽¹⁾

WHEREFORE, for all of the above reasons, defendant Luis Sanchez requests that this court enter a judgment of acquittal on Counts 1, 2, and 3.

Respectfully submitted,

FEDERAL DEFENDER PROGRAM

Terence F. MacCarthy,

Executive Director

By: ____________________________

Sergio F. Rodriguez

SERGIO F. RODRIGUEZ

LUIS M. GALVAN

FEDERAL DEFENDER PROGRAM

219 S. Dearborn Street

Suite 1142

Chicago, Illinois 60604

(312)427-3234

1. Defendant has not been able to obtain and review a Transcript of Proceedings and submits the instant motion based upon the time restrictions set. However, Defendant does not waive any error that may appear from a review of the complete Transcript of Proceedings and Record of Appeal.