Free Motion to Compel - District Court of California - California

Case 3:07-cr-03470-BEN

Document 6-4

Filed 02/11/2008

Page 1 of 1

January 15, 2008

Christopher M. Alexander Assistant United States Attorney Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Re: United States v. Beltran-Lay, 07cr3470 Dear Mr. Alexander: I understand you have been assigned to the matter of United States v. Julio Beltran-Lay. I write this letter to request specifically some discovery items that I believe are discoverable and material to the preparation of the defense. 1. Deportation hearing: Any audiotapes or other record from any deportation hearing pertaining to my client; A- file: I respectfully request a convenient appointment time to review my client's A-file; and Statements: Any other recorded statements attributed to my client.

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Thank you in advance for your time and attention to these matters. Of course, by making these requests, I seek only to identify more specifically material that I have reason to believe exists. I do not intend to waive or limit other requests I have already made or will make in the future, or other material that I am entitled to under the law. Please do not hesitate to contact me with any questions or concerns that you might have. I look forward to hearing from you. Sincerely,

TIMOTHY A. SCOTT Attorney for Julio C. Beltran-Lay