Free Response to Motion - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 2093

Filed 12/28/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 1:00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM CONCEPCION SABLAN, Defendant. ________________________________________________________________________ WILLIAM SABLAN'S RESPONSE TO THE GOVERNMENT'S MOTION TO DIVIDE WITNESS TESTIMONY

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William Sablan, through court-appointed counsel, submits this response to the government's Motion to Divide Witness Testimony. The government has requested leave to "divide or split some of it's witnesses' testimony during trial to facilitate the orderly presentation of evidence." Generally, counsel for William Sablan have no objection to the government's request. However, counsel has insufficient information to categorically agree to the government's request. Defense counsel must be advised how many witnesses the government wishes to "split" and the identity of those witnesses. Further, defense counsel cannot agree at this time to any procedure that requires piecemeal crossexamination of government witnesses or otherwise impinges on their ability to confront witnesses with thorough and coordinated cross-examinations. Dated: December 28, 2006 Respectfully submitted, /s/ Patrick J. Burke Patrick J. Burke Nathan Chambers

Case 1:00-cr-00531-WYD

Document 2093

Filed 12/28/2006

Page 2 of 2

Patrick J. Burke P.C. 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 Susan L. Foreman 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 Counsel for William Sablan

Chambers, Dansky & Mulvahill 1601 Blake Street, Suite 300 Denver, CO 80202 303-825-2222

CERTIFICATE OF SERVICE I hereby certify that on December 28, 2006, I electronically filed the foregoing Response with the Clerk of the Court using the CM/EFC system which will send notification of such filing to the following e-mail addresses: [email protected] [email protected] [email protected] [email protected] /s/ Jennifer J. Feldman