Free MOTION for Leave to File Further Motions - District Court of California - California

Case 3:07-cr-03054-IEG

Document 14

Filed 11/27/2007

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Mark A. Chambers State Bar #98933 345 West Ninth Avenue, Suite 200 Escondido, California 92025-5055 Telephone: (760) 489-1808 Fax: (760) 489-0225 [email protected] Attorney for Defendant, Alberto Minor-Olvera

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE IRMA E. GONZALEZ)

UNITED STATES OF AMERICA, Plaintiff, vs. ALBERTO MINOR-OLVERA (2), Defendant.

CASE NO. 07-CR-3054-002-IEG NOTICE OF MOTIONS AND MOTIONS TO: 1) COMPEL DISCOVERY 2) LEAVE TO FILE FURTHER MOTIONS DATE: January 7, 2008 TIME: 2:00 p.m.

TO: KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHRISTOPHER ALEXANDER, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that on January 7, 2008, at 2:00 p.m. or as soon thereafter as counsel may be heard, the defendant, Alberto Minor-Olvera, by and through his counsel, Mark A. Chambers, hereby submits the following motions and points and authorities in support thereof: // // // //
UNITED STATES v. MINOR-OLVERA Case No. 07-CR-3054-002-IEG

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Case 3:07-cr-03054-IEG

Document 14

Filed 11/27/2007

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UNITED STATES v. MINOR-OLVERA Case No. 07-CR-3054-002-IEG

I MOTIONS The defendant, Alberto Minor-Olvera, by and through his counsel, Mark A. Chambers, pursuant to Federal Rules of Criminal Procedure 12, 14, 16 and 26, the Fifth and Sixth Amendment to the Unites States Constitution, and all other applicable statutes, case law and local rules, hereby moves this Court for an Order: Compel Production of Discovery; Leave to File Further Motions; These motions are based upon the instant motions and notice of motions, the attached statements of facts and memorandum of points and authorities, and any and all other materials that may come to this Court's attention at the time of the hearing on these motions. Respectfully submitted

Dated: November 27, 2007

/s/ Mark A. Chambers MARK A. CHAMBERS Attorney for Defendant Alberto Minor-Olvera

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