Free Notice (Other) - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 2719

Filed 01/31/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 00-cr-00531-WYD-02 UNITED STATES OF AMERICA, Plaintiff, v. 1. RUDY CABRERA SABLAN, Defendant.

GOVERNMENT'S PROPOSED PROCEDURES FOR DISCLOSURE OF PRESENTENCE INVESTIGATION REPORTS FOR INMATE WITNESSES

The United States of America, by Troy A. Eid, United States Attorney for the District of Colorado, and through Brenda K. Taylor and Philip A. Brimmer, Assistant U.S. Attorneys, herein files its proposed procedures for the disclosure of pre-sentence investigation reports requested by defense counsel for Rudy Sablan. 1. Prior to the trial of William Sablan, the Court approved a procedure for the release of Pre-Sentence Investigation Reports. The government seeks to release these reports for inmate and former inmate witnesses listed by the government and by the defendant in the trial of Rudy Sablan using the same procedures. 2. The proposed procedure for disclosure, to which the parties agree, is as follows: a. Copies of the pre-sentence investigation reports shall be provided by the government to counsel for Rudy Sablan on blue paper for ease of

Case 1:00-cr-00531-WYD

Document 2719

Filed 01/31/2008

Page 2 of 4

identification; b. Such disclosure shall be subject to the "Protective Order Regarding Disclosure of Documents by the Federal Bureau of Prisons to the Defense Teams" entered on July 18, 2001and any additional conditions as set out under these procedures; c. Pre-sentence investigation reports for witnesses shall not be disseminated to the defendants or others not associated with the defense teams unless and until appropriate redactions have been made by the Bureau of Prisons; e. If it becomes necessary to use any of these pre-sentence investigation reports as exhibits in court proceedings in this case, such exhibits shall be placed under seal; and d. All copies of pre-sentence investigation reports for witnesses shall be returned to the government at the conclusion of the prosecution of Rudy Sablan. WHEREFORE, the government, with the agreement of defense counsel for Rudy Sablan, requests that the Court approve the proposed procedure and allow the disclosure of the pre-sentence investigation reports for current and former inmate witnesses called to testify in the trial of Rudy Sablan.

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Case 1:00-cr-00531-WYD

Document 2719

Filed 01/31/2008

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Respectfully submitted this 31st day of January, 2008. TROY A. EID United States Attorney

BY: s/ Brenda K. Taylor BRENDA K. TAYLOR Assistant U.S. Attorney U.S. Attorney's Office 1225 17 th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government

BY: s/ Philip A. Brimmer PHILIP A. BRIMMER Assistant U.S. Attorney U.S. Attorney's Office 1225 17 th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government

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Case 1:00-cr-00531-WYD

Document 2719

Filed 01/31/2008

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CERTIFICATE OF SERVICE I hereby certify that on this 31st day of January, 2008, I electronically filed the foregoing GOVERNMENT'S UNOPPOSED PROPOSED PROCEDURES FOR DISCLOSURE OF PRE-SENTENCE INVESTIGATION REPORTS FOR INMATE WITNESSES with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Attorneys for Rudy Sablan Forrest W. Lewis [email protected] Donald R. Knight [email protected]

s/ Veronica Ortiz VERONICA ORTIZ Legal Assistant U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone (303) 454-0100 Fax (303) 454-0403 E-mail address [email protected]

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