Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00641-JLS

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Filed 03/14/2008

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Donald A. Nunn, Esq. SBN 54232 13426 Community Road Poway, CA 92064 Telephone: (858)748-8612 Facsimile: (858)748-8610 Attorney for Defendant, Israel Morales-Amaro

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. ISRAEL MORALES-AMARO, PABLO GUZMAN-ZACARIAS, Defendants.

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Case No. 08CR0641-JLS NOTICE OF MOTION AND MOTION TO: 1) COMPEL FURTHER DISCOVERY; AND 2) LEAVE TO FILE FURTHER MOTIONS DATE: TIME: 4/11/08 1:30 p.m.

TO:

KAREN P. HEWITT, UNITED STATES ATTORNEY and SABRINA FEVE, ASSISTANT UNITED STATES ATTORNEY:

NOTICE OF MOTION PLEASE TAKE NOTICE that on April 11, 2008 at 1:30 p.m., or as soon thereafter as Counsel may be heard, the Defendant, ISRAEL MORALES-AMARO, by and through his counsel, Donald A. Nunn, will ask this Court to enter an order granting the motions listed below. /// /// _____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 1

Case 3:08-cr-00641-JLS

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MOTION ISRAEL MORALES-AMARO, the Defendant in this case, by and through his attorney, Donald A. Nunn, pursuant to the Fourth, Fifth and Sixth Amendments to the United States

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 _____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 2 __________s/Donald A. Nunn________________ Donald A. Nunn, Attorney for Defendant ISRAEL MORALESAMARO Date: March 14, 2008 Respectfully submitted, 2) Leave to file further motions. 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 matters that may come to this Court's attention prior to or at the time of the hearing on this motion. Constitution, Fed. R. Crim. P. 12, 16 and 26, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to: 1) Compel Discovery; and

Case 3:08-cr-00641-JLS

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Filed 03/14/2008

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CERTIFICATE OF SERVICE

I, Donald A. Nunn declare that: I am, and was at the time of service of the papers herein referred to, over the age of 18 years and not a party to this action; and I am employed in the County of San Diego, California. My business address is 13426 Community Road. Poway, California. I caused to be served by electronic mail on March 14, 2008: NOTICE OF MOTION AND MOTION TO COMPEL FURTHER DISCOVERY AND FOR LEAVE TO FILE FURTHER MOTIONS to the following:
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John C Ellis , Jr [email protected],[email protected] Neil R Trop [email protected] U S Attorney CR [email protected]

__s/Donald A. Nunn___________________ Donald A. Nunn, Attorney for Defendant ISRAEL MORALESAMARO

_____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 3