Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00626-JLS

Document 8

Filed 03/28/2008

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JOHN C. LEMON California Bar No. 175847
LAW OFFICES OF JOHN C. LEMON, APC

1350 Columbia Street, Suite 600 San Diego, California 92101 Telephone: (619) 794-0423 email: [email protected] Attorney for Mr. Ramirez-Perez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JANIS L. SAMMARTINO) UNITED STATES OF AMERICA, Plaintiff, v. TOMAS RAMIREZ-PEREZ, ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal No. 08cr0626-JLS Date: April 11, 2008 Time: 1:30 p.m. NOTICE OF MOTION AND MOTION TO: 1) COMPEL DISCOVERY.

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO: Defendant.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHRISTOPHER P. TENORIO, 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 defendant, Tomas Ramirez-Perez, by and through his attorney, John C. Lemon, will ask this Court to enter an order granting the motion listed below. // // // // //

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08cr0626-JLS

Case 3:08-cr-00626-JLS

Document 8

Filed 03/28/2008

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

MOTION Tomas Ramirez-Perez, the accused in this case, by and through his attorney, John C. Lemon, pursuant to the Fourth, Fifth and Sixth Amendments to the United States Constitution, Federal Rules of Criminal Procedure and all other applicable statutes, case law and local rules, hereby moves this court to grant the following motion to: 1) Compel the production of discovery.

This motion is based upon 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 the time of the hearing on this motion. Respectfully submitted,

/s/ John C. Lemon JOHN C. LEMON Attorney for Mr. Ramirez-Perez

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08cr0626-JLS