Free Motion to Compel - District Court of California - California

Case 3:08-cr-00777-L

Document 12

Filed 05/05/2008

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1 JENNIFER L. COON California State Bar No. 203913 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, CA 92101-5008 (619) 234-8467/Fax: (619) 687-2666 4 E-Mail: [email protected] 5 Attorneys for Mr. Garcia 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0777-L DATE: TIME: May 19, 2008 2:00 p.m.

11 UNITED STATES OF AMERICA, 12 13 v. 14 JOSE MANUEL GARCIA, 15 16 17 18 19 20 21 TO: 22 23 Defendant. Plaintiff,

NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) COMPEL DISCOVERY AND PRESERVE EVIDENCE; AND GRANT LEAVE TO FILE FURTHER MOTIONS

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

24 be heard, defendant Jose Manuel Garcia, by and through his attorneys, Jennifer L. Coon and 25 Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. 26 // 27 // 28 //

Case 3:08-cr-00777-L

Document 12

Filed 05/05/2008

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MOTIONS Defendant Jose Manuel Garcia, by and through his attorneys, Jennifer L. Coon and Federal Defenders

3 of San Diego, Inc., asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal 4 Procedure, and all other applicable statutes, case law, and local rules for an order to: 5 6 7 (1) (2) Compel Discovery and Preserve Evidence; and Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached statement of

8 facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any 9 and all other materials that may come to this Court's attention prior to or during the hearing of these motions. 10 11 12 DATED: 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 May 5, 2008 /s/ Jennifer L. Coon JENNIFER L. COON Federal Defenders of San Diego, Inc. Attorneys for Mr. Garcia Respectfully submitted,

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08CR0777-L