© ICE OF THE DISTRICT ATTORN FILED COUNTY OF SAN LUIS OBISPO APR 23 2015 STATEMENT OF REASONS FOR MOTION TO DISMISS, STRIKE PRIOR, OR SUBSTITUTE ean FOR RYEMICLE CODE S2agennae -AWatez. Dopuly Ce Defendant Judge ““* “2% aa Case #_(5a- 0/3: The following reasons are submitted in support of a motion made in court to dismiss, strike prior, or substitute charges regarding the pending charge of Vehicle Code §23152 Problems of Prook_/abe Access ltt difesn-. - aa Interest of Justice, with specific factors Matera pacitnar oh Coe, tor ay offense lly i- i clrwngpited oy clad =lhncactac ! G_ Otheroffense, to-wi is more properly charged becaus Deputy District Attomey: ate _. FACTUAL BASIS AND STATEMENT REGARDING CONSUMPTION OF INTOXICATING LIQUOR, OR INGESTION OF DRUGS, IN CONNECTION WITH VEHICLE CODE §23103.5 ‘The People make the following offer of proof of the facts which show that there was @ consumption of intoxicating liquor oF the ingestion or administration of a drug by the above-named defendant in connection with ihe alleged offense: The arrest and investigative reports in this case indicate the foliowing evidence of: The consumption of intoxicating liquor G__ The ingestion or administration of 3 drug Combines consumption of intoxicating liquor and the ingestion or administration of a drug: a A chemical test indicating a blood alcohol level of _-/ %. QA chemical test indicating the presence of a drug, to-wit: a QA tefusal to submit to a chemical test for alcohol ‘2 Arefusal to submit to 2 chemical test for a drug Q Erratic driving ‘1. Poor coordination (4 — Slurred speech Y — Odor of alcohal beverage Q Red, watery eyes Expert opinion of alcoho! use (2 Other evidence as Q Expert opinion of drug use follows: - Deputy District Attorney: Ubridoflher jh be Date Alas. ee