Free Motion to Admit Testimony - District Court of California - California

Case 3:07-cr-03238-WQH

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Filed 05/21/2008

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KAREN P. HEWITT United States Attorney RANDY K. JONES Assistant United States Attorney California State Bar No. 141711 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-5684 [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT

9 SOUTHERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 JUAN HERNAN LEMUS, 14 Defendant. 15 16 17 18 19 20 21 COMES NOW the Plaintiff, UNITED STATES OF AMERICA, by and through its counsel, 22 Karen P. Hewitt, United States Attorney, and Randy K. Jones, Assistant United States Attorney, and 23 hereby files its above-referenced motions in limine. 24 These motions in limine are based upon the instant motions in limine and notice of motions in 25 limine, the attached statement of the case, statement of facts and memorandum of points and authorities, 26 /// 27 /// 28 /// /// ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07CR3238-WQH DATE: TIME: June 2, 2008 2:00 p.m.

GOVERNMENT'S NOTICE OF MOTIONS AND MOTION IN LIMINE TO: 1) 2) 3) 4) 5) ADMIT EXPERT TESTIMONY; ALLOW ATTORNEY CONDUCTED VOIR DIRE; ALLOW 404(B) AND 609 EVIDENCE PRECLUDE EVIDENCE OF LEMUS' GOOD BEHAVIOR; AND PRECLUDE DEFENDANT FROM MAKING REFERENCE TO FAMILY, HEALTH, AGE, FINANCES, EDUCATION OR POTENTIAL PUNISHMENT;

Case 3:07-cr-03238-WQH

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the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions. DATED: May 21, 2008 Respectfully Submitted, KAREN P. HEWITT United States Attorney s/ Randy K. Jones

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 RANDY K. JONES Assistant United States Attorney Attorneys for Plaintiff United States of America Email: [email protected]

07CR3238-WQH

Case 3:07-cr-03238-WQH

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) Case No. 07CR3238-WQH

4 Plaintiff, 5 6 7 8 IT IS HEREBY CERTIFIED THAT: 9 10 11 12 13 14 1. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. None Jeremy Warren v. JUAN HERNAN LEMUS, Defendant.

CERTIFICATE OF SERVICE

I, RANDY K. JONES, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of Government's Notice of Motions and in Limine Motions, Statement of the Case, Statement of Facts and Memorandum of Points and Authorities in Support of Govenment's Motions in Limine on the following party by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them.

I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case:

the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct. Executed on May 21, 2008 s/ RANDY K. JONES RANDY K. JONES

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