Free Motion to Compel - District Court of California - California

Case 3:08-cr-00717-BTM

Document 11

Filed 04/08/2008

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1 ERICK L. GUZMAN California Bar No. 244391 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, CA 92101-5008 Telephone: (619) 234-8467 4 [email protected] 5 Attorneys for Mr. Castillo-Sanchez 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE BARRY T. MOSKOWITZ) 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 AURELIANO CASTILLO-SANCHEZ, 14 Defendant. 15 16 17 TO: 18 19 PLEASE TAKE NOTICE that, on April 18, 2008 at 1:30 p.m., or as soon thereafter as counsel may KAREN P. HEWITT, UNITED STATES ATTORNEY; AND JOSEPH. P ORABONA, ASSISTANT UNITED STATES ATTORNEY: ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0717-BTM DATE: April 18, 2008 TIME: 1:30 P.M. NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) COMPEL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

20 be heard, defendant, Aureliano Castillo-Sanchez, by and through his attorneys, Erick L. Guzman, and Federal 21 Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. 22 // 23 // 24 // 25 // 26 // 27 // 28 //

Case 3:08-cr-00717-BTM

Document 11

Filed 04/08/2008

Page 2 of 2

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MOTIONS Defendant, Aureliano Castillo-Sanchez, by and through his attorneys, Erick L. Guzman, and Federal

3 Defenders of San Diego, Inc., asks this Court, pursuant to the United States Constitution, the Federal Rules 4 of Criminal Procedure, and all other applicable statutes, case law, and local rules, for an order to: 5 6 7 (1) (2) Compel Discovery; 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 April 8, 2008 /s/ Erick L. Guzman ERICK L. GUZMAN Federal Defenders of San Diego, Inc. Attorneys for Mr. Castillo-Sanchez [email protected] Respectfully submitted,