Free Motion to Compel - District Court of California - California

Case 3:07-cr-03474-WQH

Document 6

Filed 02/19/2008

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1 SHAFFY MOEEL

Cal. Bar No. 238732
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

225 Broadway, Suite 900
3 San Diego, California 92101-5008

Telephone: (619) 234-8467
4 [email protected] 5

Attorneys for Mr. Herrera
6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) ) ) Plaintiff, ) ) v. ) ) JOSE SALVADOR HERRERA-TAPIA, ) ) ) Defendant. ) ) _______________________________________ ) U.S.D.C. NO. 07CR3474-WQH DATE: February 25, 2008 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) COMPEL DISCOVERY AND PRESERVE EVIDENCE; AND LEAVE TO FILE FURTHER MOTIONS

11 UNITED STATES OF AMERICA, 12 13 14 15 16 17

________________________________________

18 TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, AND

DAVID LESHNER, ASSISTANT UNITED STATES ATTORNEY:
19 20

PLEASE TAKE NOTICE that on February 25, 2008, at 2:00 p.m. or as soon thereafter as counsel may

21 be heard, the defendant, Jose Salvador Herrera-Tapia (hereinafter "Mr. Herrera"), by and through his counsel, 22 Shaffy Moeel and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the 23 following motions. 24 25 26 27 28

Case 3:07-cr-03474-WQH

Document 6

Filed 02/19/2008

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MOTIONS The defendant, Jose Salvador Herrera-Tapia, by and through his attorneys, Shaffy Moeel and Federal

3 Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal 4 Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 5 6 7

1) to compel discovery and preserve evidence; and 2) for leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached statement of

8 facts and memorandum of points and authorities, and all other materials that may come to this Court's 9 attention at the time of the hearing on these motions. 10 11 12 13 Dated: February 19, 2008 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted,

/s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Herrera

07CR3474