Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03173-H

Document 11

Filed 12/23/2007

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1 ROBERT H. REXRODE, III California State Bar No. 230024 2 427 C Street, Suite 300 San Diego, California 92101 3 Telephone: (619) 233-3169, Ext. 13 Facsimile: (619) 684-3553 4 [email protected] 5 Attorneys for Mr. Mario Barron-Galvan 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE MARILYN L. HUFF) 10 UNITED STATES OF AMERICA, 11 12 v. 13 14 MARIO BARRON-GALVAN, 15 16 17 18 TO: 19 20 KAREN P. HEWITT, UNITED STATES ATTORNEY, AND DOUGLAS KEEHN, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on January 7, 2007, at 2:00 p.m., or as soon thereafter Defendant. Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. DATE: TIME: 07cr3173-H January 7, 2007 2:00 p.m.

NOTICE OF MOTIONS: TO COMPEL DISCOVERY; FOR LEAVE TO FILE FURTHER MOTIONS; AND, (3) FOR LEAVE TO INCORPORATE MOTIONS ________________________________ (1) (2)

21 as counsel may be heard, the defendant, Mario Barron-Galvan, by and through his counsel, 22 Robert Rexrode, will ask this Court to enter an order granting the following motions. 23 24 MOTIONS The defendant, Mario Barron-Galvan, by and through his attorney, Robert Rexrode,

25 pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all 26 other applicable statutes, case law and local rules, hereby moves this Court for an order: 27 28 1) to compel discovery; 2) for leave to file further motions; and, 3) for leave to incorporate motions.

Case 3:07-cr-03173-H

Document 11

Filed 12/23/2007

Page 2 of 2

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These motions are based upon the instant motions and notice of motions, the attached

2 statement of facts and memorandum of points and authorities, and all other materials that 3 may come to this Court's attention at the time of the hearing on these motion. 4 5 6 7 Dated: December 23, 2007 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3173 /s/ Robert H. Rexrode ROBERT H. REXRODE, III Attorneys for Mr. Barron-Galvan [email protected] Respectfully submitted,