Free Motion to Compel - District Court of California - California

Case 3:08-cr-00093-JAH
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Filed 02/04/2008

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BRIDGET KENNEDY California State Bar No. 253416 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone (619) 234-8467 Facsimile (619) 687-2666 [email protected] Attorneys for FRANCISCO HERNANDEZ-FIGUEROA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JOHN A. HOUSTON) ) ) Plaintiff, ) ) v. ) ) FRANCISCO HERNANDEZ-FIGUEROA, ) ) Defendant. ) ) _ _______________________________________ ) TO: UNITED STATES OF AMERICA, Case No. 08CR0093-JAH DATE: February 19, 2008 TIME: 8:30 a.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) COMPEL DISCOVERY AND PRESERVE EVIDENCE; and (2) GRANT LEAVE TO FILE FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND PAUL L. STARITA, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on February 19, 2008 at 8:30 a.m. or as soon thereafter as counsel

may be heard, defendant, FRANCISCO HERNANDEZ-FIGUEROA, by and through his attorneys, BRIDGET KENNEDY, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // // // // // 08CR0093-JAH

Case 3:08-cr-00093-JAH
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Document 9

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MOTIONS Defendant, FRANCISCO HERNANDEZ-FIGUEROA, by and through counsel, BRIDGET KENNEDY, 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) Compel Discovery and Preserve Evidence; (2) Grant Leave to File Further Motions This motion is based upon the instant motion and notice of motion, 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/ Bridget Kennedy BRIDGET KENNEDY Federal Defenders of San Diego, Inc. [email protected] Attorneys for Mr. Hernandez-Figueroa

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