Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00063-LAB
1 CAREY D. GORDEN

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Filed 01/14/2008

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California State Bar No. 236251

2 225 Broadway, Suite 900 San Diego, CA 92101-5030 3 (619) 234-8467/Fax: (619) 687-2666 E-Mail: [email protected] 4 5 Attorneys for Mr. Garcia 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE LARRY ALAN BURNS) ) CASE NO. 08CR0063-LAB ) ) DATE: FEBRUARY 4, 2008 Plaintiff, ) TIME: 2:00 P.M. ) v. ) NOTICE OF MOTIONS AND MOTIONS ) TO: PEDRO GARCIA, ) ) (1) SUPPRESS STATEMENTS; COMPEL DISCOVERY/PRESERVE Defendant. ) (2) EVIDENCE AND ) ) (3) GRANT LEAVE TO FILE FURTHER ) MOTIONS ) ) TO: KAREN HEWITT, UNITED STATES ATTORNEY; AND CAROLINE HAN, ASSISTANT UNITED STATES ATTORNEY: UNITED STATES OF AMERICA, PLEASE TAKE NOTICE that on February 4, 2008 at 2:00 p.m, or as soon thereafter as counsel may be heard, defendant, Pedro Garcia, by and through his attorneys, Carey D. Gorden and Federal Defenders of San Diego Inc., will ask this Court to enter an order granting the following motions. /// /// /// /// 08CR0063-LAB

Case 3:08-cr-00063-LAB
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Filed 01/14/2008

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MOTIONS Defendant, Pedro Garcia, by and through his attorney, Carey D. Gorden 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) Suppress Statements; Compel Discovery/Preserve Evidence; and Grant Leave to File Further Motions.

These motions are based upon the instant motions and notice of motions, the attached
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statement of facts and memorandum of points and authorities, the files and records in the above10

captioned matter, and any and all other materials that may come to this Court's attention prior to
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or during the hearing of these motions.
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Respectfully submitted,
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Dated:

January 14, 2008

/s/ Carey D. Gorden CAREY D. GORDEN Attorney for Mr. Garcia [email protected]

08CR0063-LAB