Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:07-cr-03244-DMS

Document 24

Filed 03/06/2008

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(EX PARTE) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) No. 07CR3244-DMS EX PARTE MOTION FOR ORDER ALLOWING U.S. PROBATION TO DISCLOSE DEFENDANT'S JUVENILE RECORDS OR DOCUMENTS TO DEFENSE COUNSEL

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Plaintiff,
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BRIAN DE LA CRUZ-FLORES,
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Defendant.
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Brian De la Cruz Flores, defendant in this case, moves this Court for an order allowing U.S. Probation to disclose to his attorney, Gary Burcham, all documents or records relating to Mr. De la Cruz-Flores when he was a juvenile. This second motion relating to this issue is

required because U.S. Probation has construed this Court's March 5, 2008 order not to cover any documents not specifically created by a local, state, or federal court.

Dated:

3/6/08

/s/ Gary P. Burcham Gary P. Burcham Counsel for Defendant

Case 3:07-cr-03244-DMS

Document 24

Filed 03/06/2008

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff-Appellee, v. BRIAN DE LA CRUZ FLORES, ) ) ) ) ) ) ) ) ) U.S.D.C. No. 07CR3244-DMS CERTIFICATE OF SERVICE

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Defendant-Appellant.
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IT IS HEREBY CERTIFIED THAT:
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I, GARY P. BURCHAM, am a citizen of the United States and am at least eighteen years of age.
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My business address is 964 Fifth Avenue, Suite 300, San Diego, CA 92101.
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I am not a party to the above-entitled action. I have caused service of the Motion to Allow
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Disclosure of Defendant's Juvenile Records and Documents on the following party or parties by electronically
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filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies
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him/her.
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Aaron Clark, Esq. Assistant United States Attorney 880 Front Street San Diego, CA 92101 I declare under penalty of perjury that the foregoing is true and correct.

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Executed on March 6, 2008.
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s/ Gary P. Burcham GARY P. BURCHAM