Free Motion for Discovery - District Court of California - California

Case 3:08-cr-01096-LAB

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Filed 05/07/2008

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1 JEREMY D. WARREN California Bar No. 177900 2 105 West F Street, Fourth Floor San Diego, California 92101 3 Tel: (619) 234-4433 Email: [email protected] 4 Attorney for Defendant Rios 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 ARTURO RIOS-MENDOZA, 14 Defendant. 15 16 To: 17 18 Carol Lam, United States Attorney, and Rebecca Kanter, Assistant United States Attorney PLEASE TAKE NOTICE that as soon as counsel may be heard, the accused, Arturo Rios) ) ) ) ) ) ) ) ) ) ) Case No. 08cr1096-LAB Date: Time: May 19, 2008 2:00 p.m.

NOTICE OF MOTIONS AND MOTIONS TO 1) COMPEL DISCOVERY, 2) FOR ACCESS TO A-FILE 3) FOR LEAVE TO FILE FURTHER MOTIONS

19 Mendoza, by and through counsel, Jeremy D. Warren, will ask this Court to enter an order granting the 20 motions listed below. 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // 1 08cr1096-LAB

Case 3:08-cr-01096-LAB

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Motions Arturo Rios-Mendoz, the accused, by and through counsel, Jeremy Warren, pursuant to the

3 United States Constitution and its Amendments, Fed. R. Crim. P., and all other applicable statutes, case law 4 and local rules, hereby moves this Court for an order: 5 6 7 8 1) 2) 3) to compel discovery, for access to the A-File, and for leave to file further motions.

These motions are based upon the instant motions and notice of motions, the attached

9 statement of facts and memorandum of points and authorities, and any and all other materials that may come 10 to this Court's attention at the time of the hearing on these motions. 11 12 13 14 Dated: May 5, 2008 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08cr1096-LAB Jeremy D. Warren Attorney for Defendant Respectfully submitted, /s Jeremy Warren

Case 3:08-cr-01096-LAB

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1 2 3 I declare that:

PROOF OF SERVICE

I am a citizen of the United States and employed in the city of San Diego, CA. I am over

4 eighteen years of age. My business address is 105 West F Street, Fourth Floor San Diego, CA 92101. 5 6 7 8 9 10 11 On May 5, 2008, I personally served the following documents: Notice of Motion and Motion for Discovery, for Access to his A-File, and For Leave to File Further Motions, and Memorandum of Points and Authorities in Support of The Motions. on the below attorneys by electronic filing: Assistant United States Attorney Rebecca Kanter I declare under penalty of perjury that the foregoing is true and correct, and that this declaration

12 was executed on May 5, 2008 at San Diego, CA. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 08cr1096-LAB /s Jeremy Warren ______________________________ Jeremy D. Warren