Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:07-cr-00004-JJF

Document 28

Filed 03/20/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA VS. VANIVAN DEON FULLER MOTION FOR THE GOVERNMENT TO GIVE NOTICE OF ITS INTENTION TO USE EVIDENCE OF OTHER CRIMES, WRONGS OR BAD ACTS UNDER FED. R. EVID. 404(b) § § § §

CRIMINAL ACTION NO. 07-04

TO THE HONORABLE JOSEPH J. FARNAN, JR., UNITED STATES DISTRICT JUDGE FOR THE DISTRICT OF DELAWARE: COMES NOW VANIVAN DEON FULLER, Defendant, by and through his attorney of record, ROBERT G. TURNER, and moves this Court to order the government to provide him with notice of its intention to use evidence of "other crimes, wrongs or acts" of the Defendants, as that phrase is used in Fed. R. Evid. 404(b), and of the general nature of any such evidence it intends to introduce at trial. The undersigned has attempted to confer with Assistant United States Attorney Ilana H. Eisenstein by telephone on March 20, 2008 but was unable to speak with her. SIGNED: /s/ Robert G. Turner ROBERT G. TURNER, Bar I.D. # 3313 Texas State Bar No. 20328500 3714 Audubon Place Houston, Texas 77006 (713) 526-9575 (713) 524-2672 (Fax) Attorney for: VANIVAN DEON FULLER Date: March 20, 2008 1

Case 1:07-cr-00004-JJF

Document 28

Filed 03/20/2008

Page 2 of 2

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that a true and correct copy of the above and foregoing Motion forthe Government to Give Notice of its Intention to Use Evidence of Other Crimes, Wrongs or Bad Acts Under Fed. R. Evid. 404(b) has been delivered via electronic mail from the Clerk of the Court to Mr. Douglas McCann/Ms. Ilana H. Eisenstein, Assistant United States Attorney, on this the 20th day of March , 2008.

/s/ Robert G. Turner ROBERT G. TURNER

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Case 1:07-cr-00004-JJF

Document 28-2

Filed 03/20/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA VS. VANIVAN DEON FULLER

§ § § §

CRIMINAL ACTION NO. 07-04

ORDER

On this day came on to be heard Defendant's Motion for Government to Give Notice of Its Intention to Use Evidence of Other Crimes, Wrongs or Bad Acts Under Fed. R. Evid. 404(b), and the Court having considered the same, it is hereby GRANTED/DENIED. SIGNED and ENTERED this the day of 2008.

UNITED STATES DISTRICT JUDGE