Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03157-JLS
1 2 3 4 5 Attorneys for Mr. Bravo-Gonzalez 6 7 8

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Filed 12/20/2007

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SHAFFY MOEEL California State Bar No. 238732 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 [email protected]

UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 (HON. JANIS L. SAMMARTINO) 11 UNITED STATES OF AMERICA, 12 Plaintiff, 13 v. 14 LUIS ALBERTO BRAVO-GONZALEZ, 15 Defendant. 16 17 _________________________________ 18 19 TO: 20 21 PLEASE TAKE NOTICE that on December 21, 2007 at 9:00 a.m., Luis Alberto Bravo22 Gonzalez, by and through his attorneys, Shaffy Moeel and Federal Defenders of San Diego, Inc., will ask 23 this Court to enter an order granting the following motions: 24 (1) compelling discovery and preservation of evidence; and 25 (2) granting leave to file further motions. 26 These motions are based upon the instant motions and notice of motions, the attached statement 27 of facts and memorandum of points and authorities, the files and records in the above-captioned matter, 28 and any and all other materials that may come to this Court's attention prior to or during the hearing of KAREN P. HEWITT, UNITED STATES ATTORNEY; STEVEN DESALVO, ASSISTANT UNITED STATES ATTORNEY: ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3157-JLM DATE: December 21, 2007 TIME: 9:00 a.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) PRESERVE EVIDENCE AND COMPEL PRODUCTION OF DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

Case 3:07-cr-03157-JLS
1 2 these motions.

Document 7-2

Filed 12/20/2007

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Respectfully submitted, 3 4 Dated: December 20, 2007 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 /s/ Shaffy Moeel SHAFFY MOEEL Federal Defenders of San Diego, Inc. Attorneys for Mr. Bravo-Gonzalez