IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF ALABAMA

SOUTHERN DIVISION

UNITED STATES OF AMERICA,	)

v.	) CRIM. NO. 03-00000

JOHN DOE.	)

MOTION FOR DISCOVERY

COMES NOW the Defendant, John Doe, pursuant to Fed. R. Crim. P. 16 and S. D. AL. L. R. 16.13(d), in order to preserve any discovery issues for appeal, and requests this Court hold that discovery issues are preserved for appeal by way of this Motion, and says forth as follows:

1.	While discovery motions typically need not be filed, and are not in most cases, Local Rule 16.13(d) allows counsel to file a discovery motion to preserve discovery matters for appeal. It is with this purpose that this motion is filed.

2.	The Defendant hereby makes requests, pursuant to and as required by Fed. R. Crim. P. 16, to view, copy, inspect, etc., all discoverable evidence in this case as delineated by the rule, and makes a further request under Local Rule 16.13 for all evidence delineated by the local rule that is not otherwise covered by Rule 16. Both rules and their listings of discoverable evidence are hereby incorporated by reference.

WHEREFORE, PREMISES CONSIDERED, the Defendant asks this Court to hold this motion preserves all discovery issues for appeal which would be covered by Rule 16 or Local Rule 16.13.

Respectfully submitted,

Defense Counsel

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE

Counsel for the Defendant related to AUSA, who was standing in on the probation office conference in this matter, that this motion would be filed to preserve discovery issues for appeal. The AUSA assigned to this case will be out of town until after the filing date for motions.

Defense Counsel

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served upon AUSA by interdepartmental delivery on 2-28-03.

Defense Counsel