Free Motion to Compel - District Court of California - California

Case 3:08-cr-00972-WQH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 TO: v. RAMON VASQUEZ-CABRALES,

Document 33

Filed 04/29/2008

Page 1 of 2

LINDA LOPEZ Florida Bar No. 0177301 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone: (619) 234-8467 [email protected] Attorneys for Mr. Vasquez-Cabrales

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0972-WQH DATE: May 19, 2008 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; AND 2) LEAVE TO FILE FURTHER MOTIONS

Defendant. _________________________________

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND JOSEPH ORABONA, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on May 19, 2008, at 2:00 p.m., or as soon thereafter as counsel

19 may be heard, Defendant Ramon Vasquez-Cabrales, by and through his attorneys, Linda Lopez and Federal 20 Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. 21 22 23 24 25 26 27 28 08CR0972

Case 3:08-cr-00972-WQH 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: April 29, 2008

Document 33

Filed 04/29/2008

Page 2 of 2

MOTIONS Defendant Ramon Vasquez-Cabrales, by and through his attorneys, Linda Lopez and Federal Defenders of San Diego, Inc., moves this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order: (1) Compel discovery; and (2) Grant leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. Respectfully submitted, /s/ Linda Lopez LINDA LOPEZ Federal Defenders of San Diego, Inc. Attorneys for Mr. Vasquez-Cabrales [email protected]

08CR0972