Free Motion to Preserve Evidence - District Court of California - California

Case 3:08-cr-00645-L

Document 8

Filed 07/28/2008

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1 SHAFFY MOEEL

California State Bar No. 238732
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

225 Broadway, Suite 900
3 San Diego, CA 92101-5008

(619) 234-8467/Fax: (619) 687-2666
4 E-Mail: [email protected] 5 Attorneys for Mr. Ortega 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) ) ) Plaintiff, ) ) v. ) ) ISMAEL ORTEGA, ) ) Defendant. ) ) ) ) ______________________________________ ) Case No. 08CR0645-MJL DATE: TIME: August 25, 2008 2:00 p.m.

11 UNITED STATES OF AMERICA, 12 13 14 15 16 17

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

18 TO: 19 20

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND PAUL COOK, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on August 25, 2008 at 2:00 p.m., or as soon thereafter as counsel may

21 be heard, defendant Ismael Ortega, by and through his attorneys, Shaffy Moeel and Federal Defenders of San 22 Diego, Inc., will ask this Court to enter an order granting the following motions. 23 24 25 26 27 28

Case 3:08-cr-00645-L

Document 8

Filed 07/28/2008

Page 2 of 2

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MOTIONS Defendant Ismael Ortega, by and through his attorneys, Shaffy Moeel and Federal Defenders of San

3 Diego, Inc., moves this Court pursuant to the United States Constitution, the Federal Rules of Criminal 4 Procedure, and all other applicable statutes, case law, and local rules for an order: 5 6 7

1) 2)

Preserving Evidence and Compelling Production of Discovery; Granting Leave to File Further Motions.

This motion is based upon the instant motions and notice of motions, the attached statement of facts

8 and memorandum of points and authorities, the files and records in the above-captioned matter, and any and 9 all other materials that may come to this Court's attention prior to or during the hearing of these motions. 10 11 DATED: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted, July 28, 2008 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Ortega

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08CR0645-MJL