Free Motion to Reveal Identification of Confidential Informant - District Court of California - California

Case 3:07-cr-03236-JLS

Document 15

Filed 01/14/2008

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KASHA K. POLLREISZ California State Bar No. 204148 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5030 Telephone: (619) 234-8467, Ext. 3727 Facsimile: (619) 687-2666 [email protected] Attorneys for Mr. Crosby

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JANIS L. SAMMARTINO) UNITED STATES OF AMERICA, Plaintiff, v. TRAVIS PAUL CROSBY, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.07CR3236-JLS DATE: TIME: February 15, 2008 1:30 p.m.

NOTICE OF MOTIONS AND MOTIONS: REVEAL CONFIDENTIAL INFORMANT; (2) COMPEL DISCOVERY/PRESERVE EVIDENCE; (3) TO DISMISS THE INDICTMENT DUE TO MISINSTRUCTION OF THE GRAND JURY; (4) AND; GRANT LEAVE TO FILE FURTHER MOTIONS __________________________________ (1)

TO:

KAREN P. HEWITT, ACTING UNITED STATES ATTORNEY, AND CHRISTOPHER TENORIO, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on February 15, 2008, at 1:30 p.m. or as soon thereafter as

counsel may be heard, the defendant, Travis Crosby, by and through his counsel, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // //

Case 3:07-cr-03236-JLS

Document 15

Filed 01/14/2008

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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: January 14, 2008

MOTIONS The defendant, Travis Crosby, by and through his attorneys, Kasha K. Pollreisz and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order: 1) to reveal confidential informant; 2) to compel discovery/preserve evidence; 3) dismiss the Indictment due to misinstruction of the Grand Jury; and 4) for 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, and all other materials that may come to this Court's attention at the time of the hearing on these motions.

Respectfully submitted, s/ Kasha K. Pollreisz KASHA K. POLLREISZ Federal Defenders of San Diego, Inc. Attorneys for Mr. Crosby [email protected]

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07CR3236-JLS