IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

UNITED STATES OF AMERICA )

)

) v. ) 1:95-CR-132

)

xxxxxxxxxxxxxxxxxx )

_____________________________)

MOTION FOR DISCOVERY OF FORFEITURE

COMES NOW, Defendant xxxxxxxxx, by and through undersigned counsel, and files this Motion for Discovery of Forfeiture Case No. 89-71-VAL in the United States District Court for the Northern District of Georgia pursuant to Federal Rules of Criminal Procedure 16(a)(1)(C). As grounds for this Motion, Defendant shows the following:

(1)

Upon information and belief, Defendant xxxxxxxxxxx believes that there is information in Forfeiture Case No. 89-71-VAL in the United States District Court for the Northern District of Georgia which is material to the preparation of his defense.

(2)

Defendant requests the entire file, including but not limited to the following:

a. deposition of John Bradbury and any and all other sworn testimony;

b. notes and memorandum of all U.S. Attorneys and government agents;

c. forfeiture or seizure notices; and

d. settlement documents.

WHEREFORE, Defendant respectfully requests, pursuant to Fed. R. Crim. P. 16(a)(1)(C), that the Court order the Government to provide Defendant with the file in Forfeiture Case No. 89-71-VAL in the United States District Court for the Northern District of Georgia.

Dated: This ___ day of August, 1995.

Respectfully submitted,

___________________________

RONIT WALKER

ATTORNEY FOR:

STATE BAR NUMBER: 732553

Federal Defender Program, Inc.

Suite 3512

101 Marietta Tower

Atlanta, Georgia 30303

404/688-7530

CERTIFICATE OF SERVICE

This is to certify that I have this day served a copy of the foregoing Motion for Discover of Forfeiture upon:

Janis Gordon, Esq.

Assistant United States Attorney

479H Richard B. Russell Building

75 Spring Street, S. W.

Atlanta, Georgia 30303

by hand delivering a copy of the same.

Dated: This ___ day of August, 1995.

___________________________

RONIT WALKER

ATTORNEY FOR:  STATE BAR NUMBER: 732553

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