Free Motion to Compel - District Court of California - California

Case 3:08-cr-00101-DMS

Document 16

Filed 03/07/2008

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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 Emad Salahshoor 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) ) ) Plaintiff, ) ) v. ) ) EMAD SALAHSHOOR, ) ) Defendant. ) ) ) ) ) ) ) ) ______________________________________ ) Case No. 08CR0101-DMS DATE: TIME: March 14, 2008 11:00 a.m.

11 UNITED STATES OF AMERICA, 12 13 14 15 16 17 18 19 20

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

TO:
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KAREN P. HEWITT, UNITED STATES ATTORNEY; AND MARC CONOVER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on March 14, 2008 at 11:00 a.m., or as soon thereafter as counsel

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may be heard, defendant Emad Salahshoor, by and through his attorneys, Shaffy Moeel and Federal
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Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions.
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Case 3:08-cr-00101-DMS

Document 16

Filed 03/07/2008

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MOTIONS Defendant Emad Salahshoor, by and through his attorneys, Shaffy Moeel and Federal Defenders of

3 San 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, March 7, 2008 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Salahshoor

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08CR0101-DMS