Free Motion to Compel - District Court of California - California


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Date: April 30, 2008
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State: California
Category: District Court of California
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Case 3:07-cr-03271-WQH

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Donald A. Nunn, Esq. SBN 54232 13426 Community Road Poway, CA 92064 Telephone: (858)748-8612 Facsimile: (858)748-8610 Attorney for Defendant, RICARDO GOMEZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. TRACY ANN NELSON (1), RICARDO GOMEZ (2), Defendants.

) ) ) ) ) ) ) ) ) ) ) )

Case No. 07CR3271-WQH NOTICE OF MOTION AND MOTION TO: 1) COMPEL FURTHER DISCOVERY; AND 2) LEAVE TO FILE FURTHER MOTIONS DATE: TIME: 5/19/08 2:00 p.m.

TO:

KAREN P. HEWITT, UNITED STATES ATTORNEY and STEVE MILLER, ASSISTANT UNITED STATES ATTORNEY:

NOTICE OF MOTION PLEASE TAKE NOTICE that on May 19, 2008 at 2:00 p.m., or as soon thereafter as Counsel may be heard, the Defendant, RICARDO GOMEZ, by and through his counsel, Donald A. Nunn, will ask this Court to enter an order granting the motions listed below. /// ///

_____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 1

Case 3:07-cr-03271-WQH

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MOTION RICARDO GOMEZ, the Defendant in this case, by and through his attorney, Donald A. Nunn, pursuant to the Fourth, Fifth and Sixth Amendments to the United States Constitution,

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 2 __________s/Donald A. Nunn________________ Donald A. Nunn, Attorney for Defendant RICARDO GOMEZ Date: April 30, 2008 Respectfully submitted, 2) Leave to file further motions. This motion is based upon the instant motion and notice of motion, the attached statement of facts and memorandum of points and authorities, and any and all other matters that may come to this Court's attention prior to or at the time of the hearing on this motion. Fed. R. Crim. P. 12, 16 and 26, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to: 1) Compel Discovery; and

Case 3:07-cr-03271-WQH

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CERTIFICATE OF SERVICE

I, Donald A. Nunn declare that: I am, and was at the time of service of the papers herein referred to, over the age of 18 years and not a party to this action; and I am employed in the County of San Diego, California. My business address is 13426 Community Road. Poway, California. I caused to be served by electronic mail on April 30, 2008: NOTICE OF MOTION AND MOTION TO COMPEL FURTHER DISCOVERY AND FOR LEAVE TO FILE FURTHER MOTIONS to the following:
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Elizabeth Barros [email protected],[email protected] U S Attorney CR [email protected]

__s/Donald A. Nunn___________________ Donald A. Nunn, Attorney for Defendant RICARDO GOMEZ

_____________________________________________________ Notice Of Motion And Motion To: 1) Compel Further Discovery; And 2) Leave To File Further Motions Page 3