Free Notice (Other) - District Court of California - California

Case 3:07-cr-03211-DMS

Document 11

Filed 12/31/2007

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1 ZANDRA L. LOPEZ California Bar No. 216567 2 427 C Street, suite 300 San Diego, Ca. 92101 3 619.233.3169, ext. 17 fax: 619.684.3522 4 [email protected] 5 Attorney for Mr. Ramon Pena-Martinez 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HONORABLE DANA M. SABRAW) 11 12 UNITED STATES OF AMERICA, 13 Plaintiff, 14 v. 15 RAMON PENA-MARTINEZ 16 Defendant. 17 18 19 20 TO: 21 22 KAREN P. HEWIT, UNITED STATES ATTORNEY, AND RANDY JONES, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on January 11, 2008, at 11:00 a.m. or as soon thereafter ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07cr3211-DMS DATE: TIME: January 11, 2008 11:00 a.m.

NOTICE OF MOTIONS AND MOTIONS: (1) (2) TO COMPEL DISCOVERY; FOR LEAVE TO FILE FURTHER MOTIONS

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23 as counsel may be heard, the defendant, Ramon Pena-Martinez, by and through counsel, 24 Zandra Lopez, will ask this Court to enter an order granting the following motions. 25 26 MOTIONS The defendant, Ramon Pena-Martinez, by and through counsel, Zandra Lopez,

27 pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all 28 other applicable statutes, case law and local rules, hereby moves this Court for an order:

Case 3:07-cr-03211-DMS

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Filed 12/31/2007

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1) to compel discovery; and, 2) for leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached

3 statement of facts and memorandum of points and authorities, and all other materials that 4 may come to this Court's attention at the time of the hearing on these motions. 5 6 Respectfully submitted, 7 //s// Zandra L. Lopez 8 Dated: December 31, 2007 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3353 ZANDRA L. LOPEZ Attorney for Mr. Pena-Martinez