Free Certificate of Service - District Court of California - California

Case 3:08-cr-02430-BTM

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Filed 08/15/2008

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1 KAREN M. STEVENS

California Bar No. 110009 2 185 W. F Street, Suite 100 San Diego, California 92101 3 Telephone: (619) 239-8553 Facsimile: (619) 239-0056 4 [email protected]
5 Attorney for Gerardo Salto-Rocha 6 7

UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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(HONORABLE BARRY TED MOSKOWITZ)
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UNITED STATES OF AMERICA,
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Plaintiff,
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v.
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GERARDO SALTO-ROCHA (1),
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Defendant.
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) ) ) ) ) ) ) ) ) ) ) )

Case No. 08CR2430-1-BTM Date: August 29, 2008 Time: 1:30 p.m. NOTICE OF MOTION AND MOTIONS TO: COMPEL DISCOVERY; LEAVE TO FILE FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY, and PETER MAZZA, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on August 29, 2008, at 1:30 p.m., or as soon

20 thereafter as counsel may be heard, the defendant, Gerardo Salto-Rocha, 21 by and through his attorney, Karen M. Stevens will ask this Court to 22 issue an Order, granting the motions listed below. 23 // 24 25

MOTIONS Gerardo Salto-Rocha, by and through his attorney, pursuant to the

26 Fifth and Sixth Amendments to the United States Constitution, Federal 27 Rules of Criminal Procedure, and all other applicable statutes, case law 28 and local rules, hereby moves this Court for an Order:

Case 3:08-cr-02430-BTM

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(1) To Compel Discovery; (2) For Leave to File Further Motions. These motions are based upon the instant Motions and Notice of

4 Motions, the attached statement of facts and memorandum of points and 5 authorities, and any and all other materials 6 Court's 7 motions. 8 9 10 11 Dated: August 15, 2008 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

that may come to this

attention prior to or at the time of the hearing of these

Respectfully submitted, /s/ Karen M. Stevens KAREN M. STEVENS Attorney for Gerardo Salto-Rocha

08CR2430BTM

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Case 3:08-cr-02430-BTM

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PROOF OF SERVICE I, the undersigned, declare that:

1. I am over eighteen (18) years of age; am a resident of the County of San Diego, State of California; and my business address is 185 W.F. 4 Street, Suite 100, San Diego, California, 92101. 2. I am effecting service of DEFENDANT'S MOTIONS on the following parties by electronically filing the foregoing with the Clerk of the 6 District Court using its ECF System, which electronically notifies them:
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PETER MAZZA, Assistant U.S. Attorney Office of the U.S. Attorney 880 Front Street San Diego, CA 92101 DAVID BAKER 419 19TH Street San Diego, CA 921022

3. I hereby certify that I have mailed the foregoing, by United States Postal Service to the following non-EFC participants in this case: 13
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1. N/A mail from the United States Postal Service.

15 to the last known address, at which place there is delivery service of 16

I declare under penalty of perjury that the foregoing is true and correct. 17
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Executed on August 15, 2008 KAREN M. STEVENS

19 S/Karen M. Stevens 20 21 22 23 24 25 26 27 28

08CR2430BTM

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