UNITED STATES DISTRICT COURT

__________________ DISTRICT OF TEXAS

[DIVISION] DIVISION

UNITED STATES OF AMERICA	                 §
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[CLIENT]      	                                         §

MOTION TO DISMISS CHARGES AND BRIEF

     NOW COMES defendant [CLIENT], through undersigned counsel, and moves the Court to dismiss the indictment, or in the alternative, for an evidentiary hearing.
I.
	Defendant is charged with [CHARGE].  (REASON FOR DISMISSAL) 
	WHEREFORE, premises considered, the defendant moves that the Court dismiss the charge currently pending against him with prejudice, and, in the alternative, that the Court hold an evidentiary hearing on the validity of the deportation order.  
											
						Respectfully submitted,

						BY: __________________________
						Name
						State Bar No. [BAR NUMBER]
						Address
						City, State, Zip
						Telephone 

CERTIFICATE OF SERVICE

	I, ____________ hereby certify that on this the _______ day of [MONTH], [YEAR], a copy of the foregoing motion was hand delivered to the United States Attorney's office at ___________________________.

							                                                        								Attorney for Defendant

UNITED STATES DISTRICT COURT

______________ DISTRICT OF TEXAS
										
[DIVISION] DIVISION

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[CLIENT]     	                                                     §

ORDER

	WHEREAS, said Defendant joined by [HIS/HER] attorney filed a motion requesting that the indictment be dismissed;
	IT IS THEREFORE ORDERED that the indictment is hereby DISMISSED.
	ENTERED this ____ day of ________________, [YEAR].

							______________________________
							UNITED STATES DISTRICT JUDGE

UNITED STATES DISTRICT COURT

________________ DISTRICT OF TEXAS

[DIVISION] DIVISION

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[CLIENT]     	                                                     §

ALTERNATIVE ORDER

     Considering the motion of defendant [CLIENT] to dismiss the indictment in this matter,
     IT IS ORDERED a hearing shall be held on this matter on __________________________, [YEAR].
	Entered this ____ day of ________________________, [YEAR].

						UNITED STATES DISTRICT JUDGE