Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03214-H

Document 6

Filed 01/24/2008

Page 1 of 2

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

RICARDO M. GONZALEZ LAW OFFICES OF RICARDO M. GONZALEZ 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 Edward Douglas

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
(HONORABLE MARILYN L. HUFF) ) ) Plaintiff, ) ) v. ) ) EDWARD DOUGLAS, ) ) Defendant. ) _________________________________) TO: UNITED STATES OF AMERICA, Criminal Case No. 07-CR-02605-H Date: January 28, 2008 Time: 2:00 P.M. NOTICE OF MOTION AND MOTION FOR DISCOVERY

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND LUELLA MENDOZA CALDITO, ASSISTANT U.S. ATTORNEY PLEASE TAKE NOTICE that on January 28, 2008, at 2:00 P.M., or as soon thereafter as

counsel may be heard, defendant EDWARD DOUGLAS, by and through his counsel, Ricardo M. Gonzalez, will respectfully move the Court for an order to grant the motion as set forth below. MOTION Defendant EDWARD DOUGLAS, 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 1 07cr2605

Case 3:07-cr-03214-H

Document 6

Filed 01/24/2008

Page 2 of 2

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

disclose, or in the case of tangible evidence, to produce for inspection and 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. This motion is based upon this notice of motion, 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 this motion.

Dated: January 28, 2008

s/Ricardo M. Gonzalez RICARDO M. GONZALEZ Attorney for Defendant Edward Douglas

2

07cr2605