UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
__________________________
United States of America,
vs. Index No. 03-M-298 (GJD)
John Murtari,
Defendant
_______________________
NOTICE OF MOTION
PLEASE TAKE NOTICE, that upon the attached affidavit and upon all prior
pleadings and proceedings heretofore had herein, a Motion will be made
as follows:
DATE, PLACE AND TIME OF MOTION: In front of the Honorable Gustave J.
DiBianco at the United States Courthouse in Syracuse, New York as soon
as both sides may be heard.
TYPE OF MOTION: Defendant seeks an Order of the Court:
Staying the earlier Order of this Court, dated December 13, 2002, until
all appeals have been exhausted.
Protecting the defendant from arrest in the Federal Building for similar
conduct until all appeals have been exhausted.
Dismissing the complaint filed July 28, 2003 on the grounds that no
foundation existed for any verbal order to be issued.
Dismissing the complaint filed July 28, 2003 on the grounds the “stay
away” order was unconstitutional and overly broad.
Assigning counsel for the defendant if this matter should proceed to
trial.
Dated: July 31, 2003
Respectfully submitted,
________________________
John Murtari, pro se
34 Franklin St.
Lyons, NY 14489
(315) 635-1968