Free Motion to Compel - District Court of California - California


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Date: April 28, 2008
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State: California
Category: District Court of California
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Case 3:08-cr-01095-L

Document 7

Filed 04/28/2008

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MICHAEL J. MCCABE California Bar No. 54078 2442 Fourth Avenue San Diego, CA 92101 Telephone (619) 231-1181 Fax (619) 232-6052 Attorney for Defendant ALFONSO MONTANO-RODRIGUEZ

UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (Honorable M. James Lorenz) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MOTION The defendant, ALFONSO MONTANO-RODRIGUEZ, by and through his counsel, Michael J. McCabe, and pursuant to the provisions of the Due Process Clause to the Fifth 1 PLEASE TAKE NOTICE that on May 12, 2008, at 2:00p.m. , or as soon thereafter as counsel may be heard, the defendant, ALFONSO MONTANO-RODRIGUEZ, will move this Court for an order compelling discovery, requiring the government to give notice of its intent to use evidence, and for leave to file further motions. TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, AND TO CARLOS ARGUELLO, ASSISTANT UNITED STATES ATTORNEY: vs. ALFONSO MONTANO-RODRIGUEZ, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Crim. Case No. 08CR1095-L NOTICE OF MOTION AND MOTION TO COMPEL DISCOVERY, FOR NOTICE OF INTENT TO USE EVIDENCE, AND FOR LEAVE TO FILE FURTHER MOTIONS DATE: TIME: May 12, 2008 2:00 p.m.

Case 3:08-cr-01095-L

Document 7

Filed 04/28/2008

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Amendment to the United States Constitution, and Rules 6, 12, and 16, Federal Rules of Criminal Procedure, hereby moves this Court for an order compelling discovery, requiring the government to give notice of its intention to use evidence, and for leave to file further motions. These motions are based on the instant notice of motions and motions, the attached points and authorities, the files and records in the above-entitled case, and any and all matters that may be submitted to this Court prior to the determination of these motions.

DATED:

April 28, 2008

Respectfully submitted,

s/ Michael J. McCabe MICHAEL J. MCCABE Attorney for Defendant ALFONSO MONTANO-RODRIGUEZ

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