Free Motion to Compel - District Court of California - California

Case 3:08-cr-00649-BTM

Document 13

Filed 03/26/2008

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JOHN C. ELLIS, JR. California State Bar No. 228083 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 E-mail: [email protected] Attorneys for Mr. Mario Haro

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE BARRY T. MOSKOWITZ) UNITED STATES OF AMERICA, Plaintiff, v. MARIO HARO, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 08cr0649-BTM Date: Time: April 11, 2008 1:30 p.m.

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

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KAREN P. HEWITT, UNITED STATES ATTORNEY; AND CHRISTOPHER ALEXANDER, ASSISTANT UNITED STATES ATTORNEY:

PLEASE TAKE NOTICE that on April 11, 2008, at 1:30 p.m., or as soon thereafter as counsel may be heard, the accused, Mario Haro, 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. //// //// //// //// ////

Case 3:08-cr-00649-BTM

Document 13

Filed 03/26/2008

Page 2 of 2

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

MOTIONS Defendant, Mr. Haro, 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) 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 Mr. Haro [email protected]