Free Motion to Compel - District Court of California - California

Case 3:07-cr-03273-W

Document 12

Filed 01/14/2008

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1 JOHN C. ELLIS, JR.

California State Bar No. 228083
2 FEDERAL DEFENDERS OF SAN DIEGO, INC.

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

(619) 234-8467/Fax: (619) 687-2666
4 E-Mail: [email protected] 5 Attorneys for Alejandro Galaviz-Moreno 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS J. WHELAN) ) ) Plaintiff, ) ) v. ) ) ALEJANDRO GALAVIZ-MORENO, ) ) Defendant. ) ) ______________________________________ ) Case No. 07CR3273-W DATE: TIME: January 28, 2008 2:00 p.m.

11 UNITED STATES OF AMERICA, 12 13 14 15 16

NOTICE OF MOTIONS AND MOTIONS TO: (1) COMPEL DISCOVERY AND PRESERVE EVIDENCE; AND

(2)

GRANT LEAVE TO FILE FURTHER MOTIONS.

17 TO: 18 19

KAREN P. HEWITT, INTERIM UNITED STATES ATTORNEY; AND PAUL S. COOK, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on Monday, January 28, 2008, at 2:00 p.m., or as soon thereafter

20 as counsel may be heard, the accused, Alejandro Galaviz-Moreno, by and through his attorneys, John C. Ellis, 21 Jr., and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions listed 22 below. 23 / / 24 / / 25 / / 26 / / 27 / / 28 / /

Case 3:07-cr-03273-W

Document 12

Filed 01/14/2008

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MOTIONS Alejandro Galaviz-Moreno, the accused in this case, by and through his attorneys, John C. Ellis, Jr.,

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

1) 2)

To Compel Further Discovery and Preserve Evidence; and To Grant Leave to File Further Motions.

8 These motions are based upon the instant motions and notice of motions, the attached statement of facts and 9 memorandum of points and authorities, and any and all other materials that may come to this Court's attention 10 at the time of the hearing on these motions. 11 12 13 DATED: 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted,

January 14, 2008

/s/ John C. Ellis, Jr. JOHN C. ELLIS, JR. Federal Defenders of San Diego, Inc. Attorneys for Mr. Alejandro Galaviz-Moreno

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07CR3273-W