Free Motion to Compel - District Court of Delaware - Delaware

Case 1:07-cr-00049-JJF Document 23 Filed 06/15/2007 Pagel of2
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
Criminal Case N0. CR 07-49 JJF
UNITED STATES OF AMERICA, )
Plaintiff, g
vs. l MOTION TO COMPEL
) DISCLOSURE OF INFORMANT
GILBERTO ZARCO, )
Defendant. g O
The defendant, Gilberto Zarco, through undersigned counsel, moves the
Court for an Order requiring the govemment to disclose the identity of any
informant or informants utilized by the Govemment in the investigation of the
above-entitled matter, including the informant referenced in the DEA reports, and
all other informants, to provide copies of reports and detailed summaries of all
information provided by said informant(s) to agents involved in this case, and to
make such infoimant(s) available for interview by defendant's attorney, in
connection with defendant's pretrial motions and preparation for trial, and to
disclose the prior criminal convictions of such informants(s).
F l L E D
JUN l 5 2007
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Case 1:07-cr-00049-JJF Document 23 Filed 06/15/2007 Page 2 of 2
This motion is based upon the accompanying memorandum, the
Indictment, the records and files in the above-entitled action, and any and all other
matters which may be presented prior to or at the time of hearing of said motion.
Dated: June 15, 2007 Respectfully Submitted,
Carlos Zaldiva , LLC
j /;
y: Carlos Zaldivar
Attorney for Defendant
888B Haddon Avenue
Collingswood, NJ 08108
(856) 869-8820
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was sent via U.S.
mail on Jtme 15, 2007 to Beth Moskow-Schnoll, Assistant United States Attorney,
Nemours Building, #700, P.O. Box 2046, Wilmington, Delaware 19899—2046.
{T Carlos Zaldivar, Esquire