Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03192-IEG

Document 26

Filed 03/12/2008

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1 WILLIAM R. BURGENER State Bar Number 89508 2 1775 Hancock Street, Suite 285 San Diego, CA 92110 3 (619) 291-8565 4 5 Attorney for Defendant IVAN GARCIA OLIVER 6 7 8 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 07CR3192-IEG NOTICE OF MOTION AND MOTION TO: 1) COMPEL DISCOVERY 2) LEAVE TO FILE FURTHER MOTIONS DATE: April 7, 2008 TIME: 2:00 PM JUDGE: Hon. Gonzalez

10 UNITED STATES OF AMERICA, 11 12 vs. 13 IVAN GARCIA OLIVER, 14 15 16 TO: 17 18 Defendant. Plaintiff,

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND MELANIE K. PIERSON, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on April or as soon thereafter as counsel may be heard,

19 the defendant, Ivan Garcia Oliver, by and through his attorney William R. Burgener, will ask this 20 21 MOTION 22 23 The defendant, Ivan Garcia Oliver, by and through his attorney, William R. Burgener, Court to issue an order granting the motions listed below.

24 asks this court pursuant to the Fifth and Sixth Amendments to the United States Constitution, 25 Federal Rules of Criminal Procedure 12 and 16, and all other applicable statutes, case law and 26 local rules, hereby moves this Court for an order to: 27 28 1

Case 3:07-cr-03192-IEG

Document 26

Filed 03/12/2008

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1) compel discovery; 2) leave to file further motions. These motions are based upon the instant motions and notice of motions, the attached memorandum of points and authorities, the files and records in the above-captioned matter, and

5 6 any and all other materials that may come to this Court's attention prior to or during the hearing

7 of these motions. 8 9 10 Dated: March 12, 2008 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 s/William R. Burgener WILLIAM R. BURGENER Attorney for Defendant IVAN GARCIA OLIVER Respectfully submitted,