UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Criminal Division

UNITED STATES OF AMERICA )

)

v. ) Cr. No. xx-237 (PLF)

)

xxxxxxxxxxx xxxxxxxxxxx)

_____________________________________ )

DEFENDANT'S MOTION TO COMPEL PRODUCTION OF DISCOVERY

Defendant, by and through undersigned counsel, hereby moves this Court to compel production of the specific discovery set forth in the attached letter to government counsel. The information called for by each of the specific requests is discoverable under Federal Rule of Criminal Procedure 16 and under the Fourth, Fifth, and Sixth Amendments to the United States Constitution. It is hoped that the discovery issues raised by this letter can be worked out informally before the scheduled motions hearing in this case. However, to the extent that our informal discovery efforts are unsuccessful, we will ask that the Court order the government to provide the requested information at the time of the motions hearing on September 2, 1997.

Respectfully submitted,

A.J. KRAMER

FEDERAL PUBLIC DEFENDER

__________________________

L. Barrett Boss

Assistant Federal Public Defender 625 Indiana Avenue, N.W., Suite 550

Washington, D.C. 20004

(202) 208-7500

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Criminal Division

UNITED STATES OF AMERICA )

)

v. ) Cr. No. xx-237 (PLF)

)

xxxxxxxxxxxxxxxxxxx)

_____________________________________ )

O R D E R

Upon consideration of Defendant xxxxxxx Motion to Compel Production of Discovery, the government's Response thereto, and the entire record in this matter, it is this ________ day of _____________, 1997, hereby

ORDERED that defendant xxxxx Motion is granted; and it is further

ORDERED that the government immediately produce the discovery to the defense.

PAUL L. FRIEDMAN

U.S. DISTRICT JUDGE

Copies to:

L. Barrett Boss Sima F. Sarrafan

625 Indiana Avenue, N.W. Assistant U.S. Attorney

Suite 550 555 4th Street, N.W.

Washington, D.C. 20004 Washington, D.C. 20001

CERTIFICATE OF SERVICE

I hereby certify that on the 1st day of August 1997, the foregoing Motion to Compel Production of Discovery was served by hand upon:

Sima F. Sarrafan

Office of the United States Attorney

for the District of Columbia

555 - 4th Street, N.W.

Washington, D.C. 20001

L. Barrett Boss

Assistant Federal Public Defender