Free Motion to Compel - District Court of California - California

Case 3:08-cr-00725-DMS

Document 16

Filed 04/11/2008

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JOHN C. ELLIS, JR. JOHN C. ELLIS, JR. California State Bar No. 228083 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, CA 92101-5008 (619) 234-8467/Fax: (619) 687-2666 E-Mail: [email protected] Attorneys for Marlene Lyliann Lorenzana

6 7 8 9 10 11 12 13 14 15 Defendant. 16 17 18 TO: 19 20 21 22 23 24 25 26 27 28 KAREN P. HEWITT, UNITED STATES ATTORNEY; AND PETER MAZZA, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on April 25, 2008, at 11:00 a.m., or as soon thereafter as counsel may be heard, the accused, Marlene Lyliann Lorenzana , by and through his attorneys, John C. Ellis, Jr. and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions outlined below. //// //// //// //// //// ___________________________________ v. MARLENE LYLIANN LORENZANA (1), UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0725-DMS DATE: TIME: April 25, 2008 11:00 a.m.

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

Case 3:08-cr-00725-DMS

Document 16

Filed 04/11/2008

Page 2 of 2

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

MOTIONS Defendant, Marlene Lyliann Lorenzana , by and through his attorneys, John C. Ellis, Jr. and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to: (1) Compel Discovery/Preserve Evidence; 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, and any and all other materials that may come to this Court's attention at or before the time of the hearing on these motions. Respectfully submitted,

/s/ John C. Ellis, Jr. JOHN C. ELLIS, JR. Federal Defenders of San Diego, Inc. Attorneys for Ms. Lorenzana [email protected]