Free Motion to Compel - District Court of California - California

Case 3:07-cr-03162-L
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Document 18

Filed 12/12/2007

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CANDIS MITCHELL California Bar No. 242797 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 Facsimile: (619) 687-2666 [email protected] Attorneys for Mr. Alfredo Luis-Tenorio

7 8 9 10 SOUTHERN DISTRICT OF CALIFORNIA 11 (HONORABLE M. JAMES LORENZ) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 be heard, defendant, Alfredo Luis-Tenorio, by and through his attorneys, Candis Mitchell and Federal 26 27 28 Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. // 07CR3162-L TO: v. ALFREDO LUIS-TENORIO, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3162-L DATE: JANUARY 7, 2008 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: UNITED STATES DISTRICT COURT

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COMPEL DISCOVERY; PRESERVE EVIDENCE; GRANT LEAVE TO FILE FURTHER MOTIONS.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND EUGENE S. LITVINOFF, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on January 7, 2008, at 2:00 p.m., or as soon thereafter as counsel may

Case 3:07-cr-03162-L
1 2 3 4 5 (1) 6 7 8 9 10 11 12 13 14 15 Dated: December 12, 2007 16 17 18 19 20 21 22 23 24 25 26 27 28 (2) (3) Preserve Evidence; Compel Discovery;

Document 18

Filed 12/12/2007

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MOTIONS Defendant, Alfredo Luis-Tenorio, by and through his attorneys, Candis Mitchell and Federal Defenders of San Diego, Inc., asks this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order to:

Grant 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, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. Respectfully submitted,

s/ Candis Mitchell CANDIS MITCHELL Federal Defenders of San Diego, Inc. Attorneys for Mr. Luis-Tenorio [email protected]

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07CR3162-L