Free Motion for Discovery - District Court of California - California

Case 3:08-cr-00082-WQH

Document 7

Filed 02/04/2008

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DEBRA A. DiIORIO DiIORIO & HALL, APC California Bar No. 138018 964 Fifth Avenue, Suite 214 San Diego, California 92101 Telephone: (619) 544-1451 Facsimile: (619) 544-1473 Attorney for Defendant Perez UNITED STATES DISTRICT COURT

7 SOUTHERN DISTRICT OF CALIFORNIA 8 (HON. WILLIAM Q. HAYES) 9 UNITED STATES OF AMERICA, 10 Plaintiff, 11 v. 12 RAM IRO PEREZ, 13 Defendant. 14 15 16 17 PLEASE TAKE NOTICE that on Monday, March 10, 2008, at 2:00 p.m., or as soon 18 thereafter as counsel may be heard, the defendant, Ramiro Perez, by and through his counsel, 19 Debra A. DiIorio, will move this Court to grant the above-entitled motions. 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 // TO: ) Case No. 08-CR-0082-WQH ) ) Date: March10, 2008 ) Time: 2:00 p.m. ) ) NOTICE OF M OTIONS AND ) M OTIONS TO: ) 1) COM PEL DISCOVERY;AND ) 2) GRANT LEAVE TO FILE ) FURTHER MOTIONS ) )

KAREN HEWETT, UNITED STATES ATTORNEY, and DOUGLAS KEEHN, ASSISTANT UNITED STATES ATTORNEY

Case 3:08-cr-00082-WQH

Document 7

Filed 02/04/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: February 4, 2008

M OTIONS The defendant, Ramiro Perez, by and through his counsel, Debra A. DiIorio, and pursuant to Rules 6(e), 12, and 16 of the Federal Rules of Criminal Procedure and the Fourth, Fifth and Sixth Amendments to the United States Constitution, and all applicable local rules, hereby moves this court to 1) compel discovery; and 2) grant leave to file further motions These motions are based upon the attached memorandum, the files and records in the above-captioned matter, and any and all other evidence brought before this court before or during the hearing on this motion. Respectfully submitted,

/s/ Debra A. DiIorio DEBRA A. DiIORIO Attorney for Defendant Perez

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