Free Motion for Discovery - District Court of California - California

Case 3:08-cr-01551-JAH

Document 22

Filed 06/06/2008

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JOHN C. LEMON California Bar No. 175847
LAW OFFICES OF JOHN C. LEMON, APC

1350 Columbia Street, Suite 600 San Diego, California 92101 Telephone: (619) 794-0423 Attorney for Mr. Barrera-Santana

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JOHN A. HOUSTON) ) ) Plaintiff, ) ) v. ) ) OSCAR IGNACIO ) BARRERA-SANTANA (2), ) ) Defendant. ) ) ) TO: UNITED STATES OF AMERICA, Criminal No. 08cr1551-JAH Date: June 23, 2008 Time: 8:30 a.m.

NOTICE OF MOTION AND MOTION TO PRODUCE DISCOVERY

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KAREN P. HEWITT, UNITED STATES ATTORNEY; AND LUELLA CALDITO, ASSISTANT UNITED STATES ATTORNEY. PLEASE TAKE NOTICE that on June 23, 2008 at 8:30 a.m., or as soon thereafter as counsel may

20 be heard, the defendant, Oscar Ignacio Barrera-Santana, by and through his attorney, John C. Lemon, will 21 ask this Court to enter an order granting the motion listed below. 22 // 23 // 24 // 25 // 26 // 27 // 28 1 08cr1551-JAH

Case 3:08-cr-01551-JAH

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Filed 06/06/2008

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MOTION Oscar Ignacio Barrera-Santana, the accused in this case, by and through his attorney, John C. Lemon, pursuant to the Fourth, Fifth and Sixth Amendments to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this court to grant the following motion: 1) Compel the production of discovery.

This motion is based upon the attached statement of facts and memorandum of points and authorities, and any and all other materials that may come to this Court's attention at the time of the hearing on this motion. Respectfully submitted,

/s/ John C. Lemon JOHN C. LEMON Attorney for Mr. Barrera-Santana

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08cr1551-JAH