Free Motion to Compel - District Court of California - California

Case 3:07-cr-03055-L
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Document 6

Filed 12/21/2007

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JOHN C. ELLIS, JR. California State Bar No. 228083 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, CA 92101-5008 (619) 234-8467/Fax: (619) 687-2666 E-Mail: [email protected] Attorneys for Juan Manuel Torres-Gomez

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE M. JAMES LORENZ) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3055-L DATE: January 7, 2008 TIME: 10:00 a.m. NOTICE OF MOTIONS AND MOTIONS TO: (1) (2) (3) (4) (5) (6) COMPEL DISCOVERY/PRESERVE EVIDENCE; RELEASE GRAND JURY TRANSCRIPTS; COMPEL THE GOVERNMENT TO PROVIDE A BILL OF PARTICULARS; SUPPRESS STATEMENTS; SUPPRESS ALL EVIDENCE SEIZED IN VIOLATION OF THE FOURTH AMENDMENT; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

JUAN MANUEL TORRES-GOMEZ, Defendant.

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND STEWART M. YOUNG, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on January 7, 2008, at 10:00 a.m., or as soon thereafter as counsel

may be heard, defendant, Juan Manuel Torres-Gomez, by and through his attorneys, John C. Ellis, Jr. and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the following motions. /// /// 07CR3055-L

Case 3:07-cr-03055-L
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: December 21, 2007

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Filed 12/21/2007

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MOTIONS Defendant, Juan Manuel Torres-Gomez, by and through his attorneys, John C. Ellis, Jr. 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: (1) (2) (3) (4) (5) (6) Compel Discovery/preserve Evidence; Release Grand Jury Transcripts; Compel the Government to Provide a Bill of Particulars; Suppress Statements; Suppress All Evidence Seized in Violation of the Fourth Amendment; and 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/ John C. Ellis, Jr. JOHN C. ELLIS, JR. Federal Defenders of San Diego, Inc. Attorneys for Mr. Torres-Gomez [email protected]

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07CR3055-L