Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03244-DMS

Document 10

Filed 12/21/2007

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GARY P. BURCHAM California Bar No. 190780 2 964 Fifth Avenue; Suite 300 San Diego, CA 92101 3 Telephone: (619) 699-5930
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Attorney for Brian de la Cruz-Flores

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE DANA M. SABRAW) UNITED STATES OF AMERICA, Plaintiff, v. BRIAN DE LA CRUZ-FLORES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3244-DMS Date: January 11, 2008 Time: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; 2) FILE FURTHER MOTIONS

TO:
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KAREN P. HEWITT, UNITED STATES ATTORNEY, and ________________, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on Friday, January 11, 2008, at 2:00

p.m., or as soon thereafter as counsel may be heard, the defendant, Brian de la Cruz-Floers, by and through his attorney, Gary P. Burcham, will ask this Court to enter an order granting the motions listed below. // // // // // //

Case 3:07-cr-03244-DMS

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Filed 12/21/2007

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MOTIONS Brian de la Cruz-Flores, the defendant in this case, by and through his attorney, Gary P. Burcham, pursuant to the Amendments to the United States Constitution, Fed. R. Crim. P., and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 1) 2) to compel discovery; 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 any and all other materials that may come to this Court's attention at the time of the hearing on these motions. Respectfully submitted,

Dated: December 21, 2007

/s/ Gary P. Burcham GARY P. BURCHAM Attorney for Brian de la Cruz-Flores

07CR3244-DMS

Case 3:07-cr-03244-DMS

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Filed 12/21/2007

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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: I, GARY P. BURCHAM, am a citizen of the United States and am at least eighteen years of age. My business address is 964 Fifth Avenue,

Suite 300, San Diego, CA 92101. I am not a party to the above-entitled action. I have caused

service of Defendant's Motion For Discovery and For Leave To File Further Motions on the following party or parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies him/her. United States Attorney's Office Border Crimes Unit 880 Front Street San Diego, CA 92101

I declare under penalty of perjury that the foregoing is true and
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correct.
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Executed on December 21, 2007.
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/s/ Gary P. Burcham GARY P. BURCHAM

07CR3244-DMS