Free Motion to Compel - District Court of California - California

Case 3:08-cr-00711-JLS

Document 8

Filed 04/04/2008

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1 ERICK L. GUZMAN California Bar No. 244391 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, CA 92101-5008 Telephone: (619) 234-8467 4 [email protected] 5 Attorneys for Mr. De la Concha 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE JANIS L. SAMMARTINO) 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 FRANCISCO DE LA CONCHA, 14 15 16 17 TO: 18 19 PLEASE TAKE NOTICE that, on January 14, 2008 at 9:00 a.m., or as soon thereafter as counsel may KAREN P. HEWITT, UNITED STATES ATTORNEY; AND STEVE MILLER, ASSISTANT UNITED STATES ATTORNEY: Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0711-JLS DATE: April 18, 2008 TIME: 9:00 A.M. NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) COMPEL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

20 be heard, defendant, Francisco De la Concha, by and through his attorneys, Erick L. Guzman, and Federal 21 Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. 22 23 24 25 26 27 28

Case 3:08-cr-00711-JLS

Document 8

Filed 04/04/2008

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MOTIONS Defendant, Francisco De la Concha, by and through his attorneys, Erick L. Guzman, and Federal

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

8 facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any 9 and all other materials that may come to this Court's attention prior to or during the hearing of these motions. 10 11 12 DATED: 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 April 4, 2008 /s/ ERICK L. GUZMAN Federal Defenders of San Diego, Inc. Attorneys for Mr. De la Concha [email protected] Respectfully submitted,