Free Motion to Compel - District Court of California - California

Case 3:08-cr-00018-W

Document 8

Filed 01/15/2008

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DAVID M.C. PETERSON California Bar No. Pending FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected] Attorneys for Mr. Victor Vallin-Jauregui

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS J. WHELAN) UNITED STATES OF AMERICA, Plaintiff, v. VICTOR VALLIN-JAUREGUI, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal No. 08CR0018-W Date: February 18, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; 2) GRANT LEAVE TO FILE FURTHER MOTIONS

TO:

KAREN P. HEWITT. UNITED STATES ATTORNEY; AND DOUGLAS KEEHN, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on Monday, January 14, 2008, at 9:00 a.m., or as soon thereafter

as counsel may be heard, the accused, Victor Vallin-Jauregui, by and through his attorneys, David M.C. Peterson, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions listed below. // // // // // //

Case 3:08-cr-00018-W

Document 8

Filed 01/15/2008

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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: January 15, 2008

MOTIONS Victor Vallin-Jauregui , the accused in this case, by and through his attorneys, David M.C. Peterson, and Federal Defenders of San Diego, Inc., pursuant to the Fourth, Fifth and Sixth Amendments to the United States Constitution, Federal Rules of Criminal Procedure, Rules 8, 12, 14 and 16, and all other applicable statutes, case law and local rules, hereby moves this court for an order: 1) 2) to compel further discovery and preserve evidence; and to 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, and any and all other materials that may come to this Court's attention at the time of the hearing on these motions. Respectfully submitted,

/s/ David M.C. Peterson David M.C. Peterson Federal Defenders of San Diego, Inc. Attorneys for Mr. Vallin-Jauregui [email protected]