Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00783-DMS

Document 15

Filed 05/01/2008

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Mark A. Chambers Attorney at Law State Bar #98933 345 West Ninth Avenue, Suite 200 Escondido, California 92025-5055 Telephone: (760) 489-1808 Fax: (760) 489-0225 Attorney for Defendant, RICARDO AVALOS-RAMIREZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW)

UNITED STATES OF AMERICA, Plaintiff, vs. RICADO AVALOS RAMIREZ, Defendant.

CASE NO. 08-CR-0783-DMS NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY 2) LEAVE TO FILE FURTHER MOTIONS DATE: May 16, 2008 TIME: 11:00 a.m.

TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, AND JEFFREY D. MOORE, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on May 16, 2008, at 11:00 a.m., or as soon thereafter as counsel may be heard, the defendant, RICARDO AVALOS RAMIREZ, by and through his counsel, Mark A. Chambers, hereby submits the following motions and points and authorities in support thereof: //// //// //// ////
UNITED STATES v. AVALOS RAMIREZ CASE NO. 08-CR-0783-DMS

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Case 3:08-cr-00783-DMS

Document 15

Filed 05/01/2008

Page 2 of 2

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UNITED STATES v. AVALOS RAMIREZ CASE NO. 08-CR-0783-DMS

I MOTIONS The defendant, RICARDO AVALOS RAMIREZ, by and through his counsel, Mark A. Chambers, pursuant to Federal Rules of Criminal Procedure 12, 14, 16 and 26, the Fifth and Sixth Amendment to the Unites States Constitution, and all other applicable statutes, case law and local rules, hereby moves this Court for an Order: Compel Production of Discovery; Leave to File Further Motions; These motions are based upon the instant motions and notice of motions, the attached statements of facts and memorandum of points and authorities, and any and all other materials that may come to this Court's attention at the time of the hearing on these motions. Respectfully submitted

Dated: May 1, 2008

/s/ Mark A. Chambers MARK A. CHAMBERS Attorney for Defendant RICARDO AVALOS RAMIREZ

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