Free Motion to Compel - District Court of California - California

Case 3:08-cr-00646-WQH

Document 12

Filed 03/27/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

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. Jose Maria Salcedo

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, v. JOSE MARIA SALCEDO, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 08cr0646-WQH Date: Time: April 18, 2008 1:00 p.m.

NOTICE OF MOTION AND MOTION TO: (1) COMPEL DISCOVERY/PRESERVE EVIDENCE.

16 17 18 TO: 19 20 21 22 23 24 25 26 27 28 ___________________________________

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND ANDREW SCHOPLER, ASSISTANT UNITED STATES ATTORNEY:

PLEASE TAKE NOTICE that on April 18, 2008, at 1:00 p.m., or as soon thereafter as counsel may be heard, the accused, Jose Maria Salcedo, 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 motion outlined below. //// //// //// //// ////

Case 3:08-cr-00646-WQH

Document 12

Filed 03/27/2008

Page 2 of 2

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

MOTION Defendant, Mr. Salcedo, 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. This motion is based upon the instant motion and notice of motion, 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 this motion. Respectfully submitted,

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