Free MOTION for Leave to File Further Motions - District Court of California - California

Case 3:08-cr-00764-BEN

Document 13

Filed 04/10/2008

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James Matthew Brown (CSB# 98922) 2044 First Avenue, Suite 200 San Diego, CA. 92101 (619) 238-0815 Attorney for Defendant Jose Luis Angel Oliva-Vidrio

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6 IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
(HON. ROGER T. BENITEZ.)
UNITED STATES OF AMERICA, 10 Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Case No. 08-CR-764-BEN NOTICE OF MOTION AND MOTION FOR 1) DISCOVERY/PRESERVE EVIDENCE 2) LEAVE TO FILE MOTIONS Date: Time: Judge: 4/28/08 2:00 p.m. Hon. Roger T. Benitez

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12 13 14 15 16 17 vs. JOSE LUIS ANGEL OLIVA-VIDRIO, Defendant.

TO: THE UNITED STATES ATTORNEY and SHERRI WALKER HOBSON ASSISTANT UNITED STATES ATTORNEY:

PLEASE TAKE NOTICE that on April 28, 2008 at 2:00 p.m., or as soon thereafter as
18 counsel may be heard, before the Honorable Roger T. Benitez, United States District Court for the 19 Southern District of California, the Defendant, Jose Luis Angel Oliva-Vidrio, by and through his 20 counsel, James Matthew Brown, will ask this Court to enter an Order granting the following 21 motions: 1) to compel and preserve discovery; and 2) Leave to file additional motions. 22

MOTION
23 The defendant Jose Luis Angel Oliva-Vidrio, by and through his counsel, James Matthew 24 Brown, pursuant to United States Constitution, Fed. R. Crim. Proc., Rules 8 and 14, and applicable 25 case law and local rules, moves this Court for an Order: 1) to compel and preserve discovery; and 2) 26 Leave to file additional motions. 27 28

Case 3:08-cr-00764-BEN

Document 13

Filed 04/10/2008

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These motions are based upon the instant Motions and Notice of Motions, the attached Statements of Facts and Memorandum of Points and Authorities, the files and records in the abovecaptioned matter, and any and all other materials which may be brought to this Court's attention prior to or during the hearing on these motions. Respectfully Submitted this 10th day of April 2008.

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6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 S/James Matthew Brown James Matthew Brown Attorney of Defendant, Jose Luis Angel Oliva-Vidrio

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