Free Motion for Discovery - District Court of California - California

Case 3:07-cr-03021-WQH

Document 10

Filed 12/31/2007

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DANIEL CASILLAS, ESQ., SBN 110298 Attorney at Law 101 West Broadway, Suite 1950 San Diego, California 92101 Tel: (619) 237-3777 Fax: (619) 238-9914 Email: [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, vs. NOTICE OF MOTIONS AND MOTIONS: PEDRO CRUZ-TERCERO, Defendant. 1. COMPEL DISCOVERY 2. FILE FURTHER MOTIONS Criminal Case No. 07CR3021-WQH DATE: January 2, 2008 TIME: 2:00 p.m.

TO:

KAREN P. HEWITT, UNITED STATES ATTORNEY, AND CHRISTOPHER TENORIO, ASSISTANT UNITED STATES ATTORNEY. Please take notice that on the above date and time, or as soon thereafter as counsel may be

heard, defendant PEDRO CRUZ-TERCERO, by and through his counsel, Daniel Casillas, shall bring the above-entitled motions. MOTIONS Mr. Cruz-Tercero, by and through his counsel, Daniel Casillas, and pursuant to Rules 12 and 16 of the Federal Rules of Criminal Procedure, and the Fourth, Fifth, and Sixth Amendments of the United States Constitution, and all other applicable statutes and local rules hereby move this Court to grant the above-entitled motions. These motions are based upon the instant motions, notice of motions, the statement of facts,

07CR3021-WQH

Case 3:07-cr-03021-WQH

Document 10

Filed 12/31/2007

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and the memorandum of points and authorities, the files and records in the above-entitled case, and any and all other evidence that may come to this Court's attention prior to or at the time of the hearing on these motions. Dated: December 31, 2007 Respectfully submitted,

s/DANIEL CASILLAS DANIEL CASILLAS Attorney for Defendant PEDRO CRUZ-TERCERO

07CR3021-WQH