Free Motion to Compel - District Court of California - California

Case 3:08-cr-00690-JM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 TO: 20 21 v. JESUS HERRERA-TORRES,

Document 13

Filed 04/15/2008

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ANTHONY E. COLOMBO JR. California State Bar No. 218411 The Senator Building, 3rd Fl. 105 West "F" Street San Diego, CA 92101 (619) 236-1704 / Fax: (619) 236-1852 E-Mail: [email protected] Attorney for Mr. Jesus Herrera-Torres

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JEFFREY T. MILLER) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0690-JM DATE: May 9, 2008 TIME: 11:00 A.M. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) (4) COMPEL DISCOVERY; PRESERVE EVIDENCE; SUPPRESS STATEMENTS; AND GRANT LEAVE TO FILE FURTHER MOTIONS

Defendant.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND MARK CONOVER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on May 9, 2008 at 11:00 a.m., or as soon thereafter as counsel may

22 be heard, defendant, Jesus Herrera-Torres, by and through his attorney, Anthony E. Colombo Jr., will ask 23 this Court to enter an order granting the following motions. 24 25 26 27 28

08CR0690-JM

Case 3:08-cr-00690-JM 1 2 3 4 5 6 7

Document 13

Filed 04/15/2008

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MOTIONS Defendant, Jesus Herrera-Torres, by and through his attorney, Anthony E. Colombo Jr., asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order to: (1) (2) (3) (4) Compel Discovery; Preserve Evidence; Suppress Statements; 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 Respectfully submitted, 11 12 Dated: April 15, 2008 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 /s/ Anthony E. Colombo Jr. ANTHONY E. COLOMBO JR. Attorney for Mr. Herrera-Torres [email protected]

08CR0690-JM