Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03214-H

Document 8

Filed 01/25/2008

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RICARDO M. GONZALEZ
ATTORNEY AT LAW

California State Bar No. 98993 101 W. Broadway, Suite 1950 San Diego, California 92101 Telephone: (619) 238-9910 Fax: (619) 238-9914 Attorney for Defendant Carlos Quintero-Lopez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
(HONORABLE MARILYN L. HUFF, JUDGE) ) ) Plaintiff, ) ) v. ) ) CARLOS QUINTERO-LOPEZ, ) ) Defendant. ) _________________________________) TO: UNITED STATES OF AMERICA, Criminal Case No. 07cr3214-H Date: February 4, 2008 Time: 2:00 P.M. NOTICE OF MOTIONS AND MOTIONS FOR DISCOVERY AND TO BRING FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on February 4, 2008, at 2:00 P.M., or as soon thereafter as

counsel may be heard, defendant CARLOS QUINTERO-LOPEZ, by and through his counsel, Ricardo M. Gonzalez, will respectfully move the Court for an order to grant the motions as set forth below. MOTIONS Defendant CARLOS QUINTERO-LOPEZ, by and through his counsel, Ricardo M. Gonzalez, hereby moves this Court, pursuant to Rules 12 and 16 of the Federal Rules of Criminal Procedure, the Jencks Act (18 U.S.C. § 3500), Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, the Fourth, Fifth, and Sixth Amendments to the Constitution of the United States, and the general supervisory powers of this Court, for an Order compelling the Government to disclose, or in the case of tangible evidence, to produce for inspection and 1 07cr3214

Case 3:07-cr-03214-H

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Filed 01/25/2008

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copying, all evidence and information in the possession, custody or control of the Government which may be favorable to the defendant, or material on the issue of guilt or innocence, or which could lead to material evidence, or evidence or information which could be useful in the examination of witnesses at trial; and for disclosure and inspection of the information requested in the attached memorandum of points and authorities. The defense further moves for an order to bring further motions in the event it becomes necessary after receipt of all discovery. These motions are based upon this notice of motions, the accompanying memorandum of points and authorities, the records and files in the instant case, and on any and all other matters that may be presented to this Court prior to or at the time of the hearing of said motions.

Dated: January 25, 2008

s/Ricardo M. Gonzalez RICARDO M. GONZALEZ Attorney for Defendant Carlos Quintero-Lopez

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