Free Motion to Preserve Evidence - District Court of California - California

Case 3:07-cr-03100-JAH

Document 10

Filed 12/03/2007

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1 ERICA K. ZUNKEL California State Bar No. 229285 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, CA 92101-5008 (619) 234-8467/Fax: (619) 687-2666 4 E-Mail: [email protected] 5 Attorneys for Mr. De Leon-Arteaga 6 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JOHN A. HOUSTON) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3100-JAH DATE: TIME: December 10, 2007 10:30 a.m.

11 UNITED STATES OF AMERICA, 12 13 v. 14 ANTONIO DE LEON-ARTEAGA, 15 16 17 TO: 18 19 Defendant. Plaintiff,

NOTICE OF MOTIONS AND MOTIONS TO: 1) 2) PRESERVE EVIDENCE AND COMPEL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND NICOLE A. JONES, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on December 10, 2007, at 10:30 a.m., or as soon thereafter as counsel

20 may be heard, defendant, Antonio De Leon-Arteaga, by and through his attorneys, Erica K. Zunkel and 21 Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / /

Case 3:07-cr-03100-JAH

Document 10

Filed 12/03/2007

Page 2 of 2

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MOTIONS Defendant, Antonio De Leon-Arteaga, by and through his attorneys, Erica K. Zunkel and

3 Federal Defenders of San Diego, Inc., asks this Court pursuant to the United States Constitution, the 4 Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order 5 to: 6 7 8 (1) (2) Preserve Evidence and Compel Discovery; and Grant Leave to File Further Motions.

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

9 facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any 10 and all other materials that may come to this Court's attention prior to or during the hearing of these motions. 11 12 13 DATED: 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 December 3, 2007 /s/ Erica K. Zunkel ERICA K. ZUNKEL Federal Defenders of San Diego, Inc. Attorneys for Antonio De Leon-Arteaga Respectfully submitted,

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07CR3100-JAH