Free Motion to Compel - District Court of California - California

Case 3:07-cr-03210-W

Document 10

Filed 12/14/2007

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ROBERT L. SWAIN Attorney at Law California Bar No. 144163 964 Fifth Avenue, Suite 214 San Diego, California 92101 Telephone: (619) 544-1494 Facsimile: (619) 544-1473 E-mail: [email protected] Attorney for Defendant Macedo De La Cruz

6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HON. THOMAS J. WHELAN) 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 JOSE MACEDO-DE LA CRUZ, 14 Defendant. 15 16 17 PLEASE TAKE NOTICE that on Monday, January 28, 2008, at 2:00 p.m., or as soon 18 thereafter as counsel may be heard, the defendant, Jose Macedo-De La Cruz, by and through 19 his counsel, Robert L. Swain, will move this Court to grant the above-entitled motions. 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 TO: ) ) ) ) ) ) ) ) ) ) Case No. 07-CR-3210 Date: January 28, 2008 Time: 2:00 p.m. NOTICE OF MOTION AND MOTION TO: 1)COMPEL DISCOVERY; AND 2) LEAVE TO FILE FURTHER MOTIONS

KAREN L. HEWITT, UNITED STATES ATTORNEY, and REBECCA S. KANTER, ASSISTANT UNITED STATES ATTORNEY

Case 3:07-cr-03210-W

Document 10

Filed 12/14/2007

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1 2 3 4 5 6 7 8 9 10 11 12 13 Dated: December 14, 2007 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MOTIONS The defendant, Jose Macedo-De La Cruz, by and through his counsel, Robert L. Swain, and pursuant to Rules 6(e), 12, and 16 of the Federal Rules of Criminal Procedure and the Fourth, Fifth and Sixth Amendments to the United States Constitution, and all applicable local rules, hereby moves this court to 1) compel further discovery; and 2) leave to file further motions These motions are based upon the attached memorandum, the files and records in the above-captioned matter, and any and all other evidence brought before this court before or during the hearing on this motion. Respectfully submitted,

/s/ Robert L. Swain ROBERT L. SWAIN Attorney for Defendant Macedo-De La Cruz

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