Free Motion to Preserve Evidence - District Court of California - California

Case 3:08-cr-01195-WQH

Document 14

Filed 05/19/2008

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1 SHAFFY MOEEL

California State Bar No. 238732
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

225 Broadway, Suite 900
3 San Diego, CA 92101-5008

(619) 234-8467/Fax: (619) 687-2666
4 E-Mail: [email protected] 5 Attorneys for Mr. Muldrow 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) ) ) Plaintiff, ) ) v. ) ) TYGE ERIK MULDROW, ) ) Defendant. ) ) ) ) ______________________________________ ) Case No. 08CR1195-WQH DATE: TIME: May 19, 2008 1:30 p.m.

11 UNITED STATES OF AMERICA, 12 13 14 15 16 17

NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) PRESERVE EVIDENCE AND COMPEL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS

18 TO: 19 20

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND PAUL COOK, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on May 19, 2008 at 1:30 p.m., or as soon thereafter as counsel may

21 be heard, defendant Tyge Erik Muldrow, by and through his attorneys, Shaffy Moeel and Federal Defenders 22 of San Diego, Inc., will ask this Court to enter an order granting the following motions. 23 24 25 26 27 28

Case 3:08-cr-01195-WQH

Document 14

Filed 05/19/2008

Page 2 of 2

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MOTIONS Defendant Tyge Erik Muldrow, by and through his attorneys, Shaffy Moeel and Federal Defenders

3 of San Diego, Inc., moves this Court pursuant to the United States Constitution, the Federal Rules of Criminal 4 Procedure, and all other applicable statutes, case law, and local rules for an order: 5 6 7

1) 2)

Preserving Evidence and Compelling Production of Discovery; Granting Leave to File Further Motions.

This motion is based upon the instant motions and notice of motions, the attached statement of facts

8 and memorandum of points and authorities, the files and records in the above-captioned matter, and any and 9 all other materials that may come to this Court's attention prior to or during the hearing of these motions. 10 11 DATED: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted, May 19, 2008 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Muldrow

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08CR1195-WQH