Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00802-JAH

Document 9

Filed 04/07/2008

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DAVID M.C. PETERSON California State Bar No. 254498 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected] Attorneys for Mr. Fernandez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JOHN A. HOUSTON) ) ) Plaintiff, ) ) v. ) ) JOSE JUAN FERNANDEZ, ) ) ) Defendant. ) ) ) ) ) ) ) ) _____________________________________ ) TO: UNITED STATES OF AMERICA, Case No.: 08cr0802-JAH Date: Time: April 21, 2008 8:30 a.m.

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

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND PAUL STARITA, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on March 24 2008, at 2:00 p.m., or as soon thereafter as counsel

may be heard, the accused, Jose Juan Fernandez, by and through his attorneys, David M.C. Peterson and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions outlined below. //

08cr0802-JAH

Case 3:08-cr-00802-JAH

Document 9

Filed 04/07/2008

Page 2 of 2

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MOTIONS Defendant, Mr. Fernandez, by and through his attorneys, David M.C. Peterson and Federal Defenders of San Diego, Inc., pursuant 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 for an order to: (1) (2) Compel Discovery; and Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached statement of 7 facts and memorandum of points and authorities, and any and all other materials that may come to this 8 Court's attention at or before the time of the hearing on these motions. 9 Respectfully submitted, 10 11 DATED: April 7, 2008 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08cr0802-JAH /s/ David M.C. Peterson David M.C. Peterson Federal Defenders of San Diego, Inc. Attorneys for Mr. Fernandez E-mail: [email protected]