Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00299-W 1 2 3 4 Attorney for Mr. Avalos 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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Filed 04/01/2008

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SIRI SHETTY California State Bar No. 208812 110 West "C" Street #1810 San Diego, CA 92101 (619) 602-8479/Fax: (619) 232-7735 E-Mail: [email protected]

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS J. WHELAN) ) CASE NO. 08CR0299-W ) Plaintiff, ) DATE: APRIL 10, 2008 ) TIME: 9:00 A.M. v. ) ) NOTICE OF MOTIONS AND MOTIONS TO: PEDRO AVALOS (2), ) ) (1) DISMISS THE INDICTMENT FOR Defendant. ) GRAND JURY VIOLATION; ) (2) COMPEL DISCOVERY/PRESERVE ) EVIDENCE; AND ) (3) GRANT LEAVE TO FILE FURTHER ) MOTIONS ) TO: KAREN HEWITT, UNITED STATES ATTORNEY, AND STEPHEN DESALVO, ASSISTANT UNITED STATES ATTORNEY: UNITED STATES OF AMERICA, PLEASE TAKE NOTICE that on April 10, 2008 at 9:00 a.m., or as soon thereafter as counsel may be heard, defendant, Pedro Avalos, by and through his attorney, Siri Shetty, will ask this Court to enter an order granting the following motions.

08CR0299-W

Case 3:08-cr-00299-W 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: April 1, 2008

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Filed 04/01/2008

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MOTIONS Defendant, Pedro Avalos, by and through his attorney, Siri Shetty, asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order to: (1) (2) (3) Dismiss the Indictment for Grand Jury Violation; Compel Discovery/Preserve Evidence; and Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. Respectfully submitted, /s/ Siri Shetty SIRI SHETTY Attorney for Mr. Avalos [email protected]

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