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

Case 1:00-cr-00531-WYD

Document 2585

Filed 06/20/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. RUDY CABRERA SABLAN, et al. Defendant. ______________________________________________________________________________ MOTION FOR RELEASE OF JUROR CONTACT INFORMATION ______________________________________________________________________________ Rudy Sablan, by and through counsel, requests an order authorizing and directing the release of the names and contact information for the jurors who served in William Sablan's trial. As grounds for the release of this material, Mr. Sablan states as follows: 1. The Court granted the Defendant's motions for severance in this capital murder

case. The case against William Sablan proceeded to trial in January 2007. The jury found him guilty of murder in the first degree but could not reach a unanimous verdict in the penalty hearing, resulting in a life sentence. 2. Most of the witnesses and evidence received in William's trial will also be

presented in Rudy's trial. Exploring and evaluating the perceptions, observations and opinions of William's jurors on various witnesses and evidence is important trial preparation for Rudy's defense team. It is essential to effective investigation, trial preparation and development of trial strategy for Rudy Sablan. Effective investigation, an integral part of effective assistance of counsel, is mandated by the Sixth Amendment to the United States Constitution.

Case 1:00-cr-00531-WYD

Document 2585

Filed 06/20/2007

Page 2 of 2

3.

Consistent with local practice, Mr. Sablan seeks Court permission prior to making

any attempt to contact any of the jurors. This is a part of the investigation and trial preparation which must proceed expeditiously, however. Accordingly, Mr. Sablan will ask the Court to rule on this motion either at or prior to the July 31, 2007 status conference-scheduling hearing. 4. Counsel has been advised that the Government objects to this motion. Respectfully submitted, s/ Forrest W. Lewis Forrest W. Lewis FORREST W. LEWIS, P.C. 1600 Broadway, Suite 1525 Denver, Colorado 80202 Telephone: (303) 830-2190 Facsimile: (303) 830-1466 E-mail: [email protected] Donald R. Knight KNIGHT & MOSES, LLC 7852 S. Elati Street, Suite 201 Littleton, Colorado 80120 Telephone: (303) 797-1645 Facsimile: (303) 798-3872 E-mail: [email protected] Attorneys for Defendant Rudy Sablan CERTIFICATE OF SERVICE I hereby certify that the foregoing MOTION FOR RELEASE OF JUROR CONTACT INFORMATION was electronically filed with the Clerk of the Court using the CM/ECF system on this 20th day of June, 2007, which will send notification of such filing to the to the following e-mail addresses: Brenda Taylor [email protected] Philip Brimmer [email protected]

s/Polly Ashley