Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03101-LAB

Document 14

Filed 12/11/2007

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1 LINDA LOPEZ

Florida Bar No. 0177301
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. Julio Martinez-Hernandez 6 7 8 9 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE LARRY A. BURNS) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3101-LAB DATE: December 17, 2007 TIME: 2:00 p.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) COMPEL DISCOVERY; SUPPRESS STATEMENTS; AND GRANT LEAVE TO FILE FURTHER MOTIONS

11 UNITED STATES OF AMERICA, 12 13 v. 14 JULIO MARTINEZ-HERNANDEZ, 15 16 17 18 TO: 19 20

Plaintiff,

Defendant.

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND DALE BLANKENSHIP, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that, on December 17, 2007, at 2:00 p.m., or as soon thereafter as counsel

21 may be heard, the defendant, JULIO MARTINEZ-HERNANDEZ, by and through counsel, Linda Lopez and 22 Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the pretrial motions listed. 23 24 25 26 27 28

Case 3:07-cr-03101-LAB

Document 14

Filed 12/11/2007

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MOTIONS The defendant, JULIO MARTINEZ-HERNANDEZ, by and through attorneys, Linda Lopez and

3 Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of 4 Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves the Court for 5 an order to: 6 7 8 9

1) 2) 3)

Compel discovery; Suppress statement; and Grant leave to file to file further motions.

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

10 facts and memorandum of points and authorities, and all other materials that may come to the Court's attention 11 at the time of the hearing on these motions. 12 13 14 DATED: 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted,

December 11, 2007

/s/ Linda Lopez LINDA LOPEZ Federal Defender of San Diego, Inc. Attorneys for Mr. Martinez-Hernandez

2

07CR3101