Free Motion for Discovery - District Court of California - California


File Size: 42.1 kB
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Date: March 10, 2008
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State: California
Category: District Court of California
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Case 3:08-cr-00337-H

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Filed 03/10/2008

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CHARLES L. REES California Bar No. 200682 LAW OFFICES OF CHARLES L. REES 424 F Street, Suite D San Diego, California 92101 Telephone: (619) 239-9300 Fax: (619) 702-5415 Email: [email protected] Attorney for Mr. Jose Francisco Perez-Gomez

6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HONORABLE MARILYN L. HUFF) 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 JOSE FRANCISCO PEREZ-GOMEZ (3), 15 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that as soon as counsel may be heard, defendant, Jose Francisco Perez-Gomez, by and through his attorney, Charles L. Rees, will ask this Court to enter an order granting the following motions. // // // // // 1 08CR337H TO: KAREN P. HEWITT, UNITED STATES ATTORNEY; AND REBEKAH YOUNG, ASSISTANT UNITED STATES ATTORNEY. ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal No. 08CR337H Date: March 24, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) COMPEL DISCOVERY AND PRESERVE EVIDENCE (2) GRANT LEAVE TO FILE FURTHER MOTIONS

Case 3:08-cr-00337-H

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MOTIONS Jose Francisco Perez-Gomez, by and through his attorney, Charles L. Rees, pursuant to the Fourth, Fifth and Sixth Amendments to the United States Constitution, FED. R. CRIM. P. 12, 16 and 26, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to: 1) Compel discovery and preserve evidence; and

6 2) Grant leave to file further motions 7 These motions are based upon the instant Notice of Motions and Motions, the attached Facts 8 and Memorandum of Points and Authorities, the files and records in this case, and any and all other materials 9 that may come to this Court's attention prior to or during the hearing of these motions. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08CR337H Dated: March 10, 2008 /s/CHARLES L. REES Attorney for Mr. Jose Francisco Perez-Gomez Respectfully submitted,

Case 3:08-cr-00337-H

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