Free Motion to Compel - District Court of California - California

Case 3:08-cr-00014-WQH
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 TO: v. JUAN BARRERA-BARRERA, Defendant.

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KRIS J. KRAUS California State Bar No. 233699 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected] Attorneys for Mr. Juan Barrera-Barrera

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) CASE NO. 08CR0014-WQH DATE: February 11, 2008 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) COMPEL DISCOVERY; PRESERVE EVIDENCE; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHRISTINA McCALL, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on February 11, 2008, at 2:00 p.m., or as soon thereafter as counsel

may be heard, defendant, Juan Barrera-Barrera, by and through his attorneys, Kris J. Kraus, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // // // // // // 1 08CR0014-WQH

Case 3:08-cr-00014-WQH
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: January 28, 2008

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MOTIONS Defendant, Juan Barrera-Barrera, by and through his attorneys, Kris J. Kraus, 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) 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 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/ Kris J. Kraus KRIS J. KRAUS Federal Defenders of San Diego, Inc. Attorneys for Mr. Juan Barrera-Barrera [email protected]

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Case 3:08-cr-00014-WQH
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: January 28, 2008

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of his information and belief, and that a copy of the foregoing document has been served this day upon: Christina McCall U S Attorneys Office Southern District of California 880 Front Street Room 6293 San Diego, CA 92101 (619)557-5610 Fax: (619)557-5917 Email: [email protected]

/s/ Kris J. Kraus KRIS J. KRAUS Federal Defenders 225 Broadway, Suite 900 San Diego, CA 92101-5030 (619) 234-8467 (tel) (619) 687-2666 (fax) e-mail: [email protected]

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