Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00094-JLS

Document 6

Filed 01/18/2008

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ROBERT C. SCHLEIN California State Bar No. 97876 401 "B" Street, Suite 2209 San Diego, CA 92101 Telephone: (619) 235-9026 Email: [email protected] Attorney for EZEQUIEL MANZO-GAITAN

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Defendant's Motions to Compel Discovery and Grant Leave to File Further Motions 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JANIS L. SAMMARTINO) ) ) Plaintiff, ) ) v. ) ) EZEQUIEL MANZO-GAITAN, ) ) Defendant. ) ) ____________________________________) UNITED STATES OF AMERICA, Case: 08CR00094-JLS Date: February 15, 2008 Time: 1:30 p.m. MOTIONS TO: (1) COMPEL DISCOVERY; (2) GRANT LEAVE TO FILE FURTHER MOTIONS

TO: KAREN P. HEWITT, UNITED STATES ATTORNEY AND REBECCA KANTER, ASSISTANT UNITED STATES ATTORNEY: MOTIONS Defendant, Ezequiel MANZO-GAITAN, by and through his attorney, Robert C. Schlein, 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) Compel Discovery; and Grant Leave to File Further Motions.

Case 3:08-cr-00094-JLS

Document 6

Filed 01/18/2008

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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,

Dated: January 18, 2008

/s/ROBERT C. SCHLEIN Robert C. Schlein Attorney-at-Law Attorney for Defendant MANZO-GAITAN [email protected]

Defendant's Motions to Compel Discovery and Grant Leave to File Further Motions 2