Free Motion to Compel - District Court of California - California

Case 3:08-cr-00067-JM
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Document 11

Filed 01/29/2008

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CANDIS MITCHELL California State Bar No. 242797 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 (619) 234-8467 (tel); (619) 687-2666 (fax) [email protected] Attorneys for Mr. Gabino Alberto Rodriguez-Lara

6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HONORABLE JOHN JEFFREY T. MILLER) 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 Gabino Alberto Rodriguez-Lara, 15 Defendant. 16 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that on February 29, 2008, at 11:00 a.m., or as soon thereafter as counsel may be heard, defendant, Gabino Alberto Rodriguez-Lara, by and through his attorneys, Candis Mitchell and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. /// /// /// /// 08CR0067-JM TO: ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 08CR0067-JM DATE: FEBRUARY 29, 2008 TIME: 11:00 a.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) (4) COMPEL DISCOVERY; PRESERVE EVIDENCE; RE-WEIGH NARCOTIC EVIDENCE, AND; GRANT LEAVE TO FILE FURTHER MOTIONS.

KAREN HEWITT, INTERIM UNITED STATES ATTORNEY, AND TO BE DETERMINED, ASSISTANT UNITED STATES ATTORNEY:

Case 3:08-cr-00067-JM
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Document 11

Filed 01/29/2008

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MOTIONS Defendant, Gabino Alberto Rodriguez-Lara, by and through his attorneys, Candis Mitchell and Federal Defenders of San Diego, Inc., asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order to: (1) (2) (3) (4) Compel Discovery; Preserve Evidence; Re-Weigh Narcotic Evidence; and Grant 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, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. Respectfully submitted, s/ Candis Mitchell CANDIS MITCHELL Federal Defenders of San Diego, Inc. Attorneys for Mr. Rodriguez-Lara [email protected]

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08CR0067-JM