Free Motion for Discovery - District Court of California - California


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Date: January 14, 2008
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State: California
Category: District Court of California
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Case 3:08-cr-00081-IEG

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Filed 01/14/2008

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1 ROBERT H. REXRODE, III California State Bar No. 230024 2 427 C Street, Suite 300 San Diego, California 92101 3 Telephone: (619) 233-3169, Ext. 13 Facsimile: (619) 684-3553 4 [email protected] 5 Attorneys for Mr. Cesar Hernandez-Guillen 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE IRMA E. GONZALEZ) 10 UNITED STATES OF AMERICA, 11 12 v. 13 14 CESAR HERNANDEZ-GUILLEN, 15 16 17 TO: 18 19 KAREN P. HEWITT, UNITED STATES ATTORNEY, AND JEFFREY MOORE, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on January 28, 2008, at 2:00 p.m., or as soon thereafter Defendant. Plaintiff, ) ) ) ) ) ) ) ) ) ) ) CASE NO. DATE: TIME: 08cr0081-IEG January 28, 2008 2:00 p.m.

NOTICE OF MOTIONS: TO COMPEL DISCOVERY; AND, FOR LEAVE TO FILE FURTHER MOTIONS ________________________________ (1) (2)

20 as counsel may be heard, the defendant, Cesar Hernandez-Guillen, by and through his 21 counsel, Robert Rexrode, will ask this Court to enter an order granting the following 22 motions. 23 24 MOTIONS The defendant, Cesar Hernandez-Guillen, by and through his attorney, Robert

25 Rexrode, pursuant to the United States Constitution, the Federal Rules of Criminal 26 Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court 27 for an order: 28 1) to compel discovery; and,

Case 3:08-cr-00081-IEG

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2) for leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached

3 statement of facts and memorandum of points and authorities, and all other materials that 4 may come to this Court's attention at the time of the hearing on these motion. 5 6 7 8 Dated: January 14, 2008 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 08cr0081 /s/ Robert H. Rexrode ROBERT H. REXRODE, III Attorneys for Mr. Hernandez-Guillen [email protected] Respectfully submitted,