Free Motion to Compel - District Court of California - California

Case 3:07-cr-03289-W

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Filed 01/30/2008

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KASHA K. POLLREISZ California State Bar No. 204148 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone: (619) 234-8467, Ext. 3727 Facsimile: (619) 687-2666 [email protected] Attorneys for Mr. Barragan-Tapia

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS J. WHELAN)

UNITED STATES OF AMERICA, Plaintiff, v. JONATHAN BARRAGAN-TAPIA, Defendant.

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CASE NO.07CR3289-TJW DATE: TIME: February 11, 2008 2:00 p.m.

NOTICE OF MOTIONS AND MOTIONS: TO COMPEL DISCOVERY/PRESERVE EVIDENCE; (2) GRANT SEVERANCE OF CODEFENDANTS; (3) AND; GRANT LEAVE TO FILE FURTHER MOTIONS __________________________________ (1)

TO:

KAREN P. HEWITT, ACTING UNITED STATES ATTORNEY, AND JOHN PARMLEY, 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, the defendant, Jonathan Barragan-Tapia, by and through his counsel, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. //

Case 3:07-cr-03289-W

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Filed 01/30/2008

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MOTIONS The defendant, Jonathan Barragan-Tapia, by and through his attorneys, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 1) to compel discovery/preserve evidence; 2) grant severance; and 3) for 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 all other materials that may come to this Court's attention at the time of the hearing on these motions.

Respectfully submitted, /s/ Kasha K. Pollreisz KASHA K. POLLREISZ Federal Defenders of San Diego, Inc. Attorneys for Mr. Barragan-Tapia [email protected]

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