Free Motion to Compel - District Court of California - California

Case 3:07-cr-03029-BTM

Document 15

Filed 07/18/2008

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ERICK L. GUZMAN California State Bar No. 244391 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467 E-mail: [email protected] Attorneys for Mr. Caperon

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE BARRY T. MOSKOWITZ) ) ) Plaintiff, ) ) v. ) ) VICTOR LUIS CAPERON, ) ) Defendant. ) ) ) _____________________________________ ) UNITED STATES OF AMERICA, TO: Case No.: 07CR3029-BTM Date: Time: July 25, 2008 1:30 p.m.

NOTICE OF MOTIONS AND MOTIONS TO: (1) COMPEL DISCOVERY; AND (2) LEAVE TO FILE FURTHER MOTIONS.

KAREN P. HEWITT, UNITED STATES ATTORNEY; AND REBECCA KANTER, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that on July 25, 2008, at 1:30 p.m., or as soon thereafter as counsel may

be heard, the accused Victor Luis Caperon, by and through his attorneys, Erick L. Guzman and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the motions outlined below. /// /// /// /// /// ///

Case 3:07-cr-03029-BTM

Document 15

Filed 07/18/2008

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1 2 3 4 5 6 7 8 9 10 11 12 Dated: July 18, 2008 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MOTIONS Defendant, Mr. Caperon, by and through his attorneys, Erick L. Guzman and Federal Defenders of San Diego, Inc., pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order to: (1) Compel Discovery; and (2) 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, and any and all other materials that may come to this Court's attention at or before the time of the hearing on these motions. Respectfully submitted,

/s/ Erick L. Guzman ERICK L. GUZMAN Federal Defenders of San Diego, Inc. Attorneys for Mr. Caperon [email protected]