Free Motion to Compel - District Court of California - California

Case 3:07-cr-03270-W

Document 25

Filed 02/10/2008

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LEE PLUMMER California State Bar Number 77783 Attorney at Law 4045 Bonita Rd. #202 Bonita, Ca. 91902 Telephone: (619) 267-1710 Attorney for Defendant Jonathan Astorga Madrigal UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE THOMAS WHELAN) UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07-CR-3270-W Date: March 10, 2008 Time: 2:00 P.M. NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY; AND 2) LEAVE TO FILE FURTHER MOTIONS

11 Plaintiff, 12 v. 13 JONATHAN ASTORGA MADRIGAL, 14 Defendant. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO:

KAREN HEWITT, UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on Monday , March 10, 2008, at 2:00 P.M.,

or as soon thereafter as counsel may be heard, the defendant, Jonathan Astorga Madrigal, by and through counsel, LEE PLUMMER will ask this Court to issue an order granting the motions listed below. // // // -1-

Case 3:07-cr-03270-W

Document 25

Filed 02/10/2008

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1 2 3 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 Dated: February 11, 2008

MOTIONS The defendant, Jonathan Astorga Madrigal, by and through counsel, LEE PLUMMER, asks this Court pursuant to the Fifth and Sixth Amendments, to the United States Constitution, Fed. R. Crim. P. 12, 16 and 26, and all other applicable statutes and local rules for an order to: 1) Compel Discovery; and 2) 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, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions.

Respectfully submitted,

/s/ Lee Plummer Attorney for Defendant

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