Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03419-WQH

Document 16

Filed 02/07/2008

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Wendy S. Gerboth Attorney At Law California Bar No. 167687 964 Fifth Avenue, Suite 214 San Diego, California 92101 Facsimile: (619) 699-5967 Telephone: (619) 699-5969 [email protected] Attorney for Defendant Huante-Hernandez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, v. DALIA HUANTE-HERNANDEZ Defendant. ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07-CR-3419-WQH Date: February 19, 2008 Time: 2:00 p.m. DEFENDANT'S NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; AND 2) GRANT LEAVE TO FILE FURTHER MOTIONS

TO:

KAREN P. HEWITT, UNITED STATES ATTORNEY; and JEFFREY MOORE, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on Tuesday, February 19, 2008 at 2:00 p..m., or as soon

thereafter as counsel may be heard, the defendant, Dalia Huante-Hernandez, by and through her counsel Wendy S. Gerboth, will move this Court to compel discovery and grant leave to file further motions after discovery is complete. // // // // // //

Case 3:07-cr-03419-WQH

Document 16

Filed 02/07/2008

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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 7, 2008

M OTIONS The defendant, Dalia Huante-Hernandez, by and through her counsel Wendy S. Gerboth, pursuant to Fed. R. Crim. P. 12, 16 and 26.2 and Title 21, United States Code Sections 952 and 960, and the First, Fourth, Fifth and Sixth Amendments to the United States Constitution, hereby moves this Court to compel discovery and grant leave to file further motions after discovery is complete. These motions are based upon the instant motions, the notice of motions, the attached statement of facts and memorandum of points and authorities, the files and records in the above-entitled cause, and any and all other information that may be brought to the Court's attention prior to or during the hearing on these motions. Respectfully submitted,

/s/ Wendy S. Gerboth WENDY S. GERBOTH Attorney for Defendant Huante

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