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

Case 3:07-cr-03100-JAH

Document 24

Filed 04/28/2008

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KAREN P. HEWITT United States Attorney NICOLE ACTON JONES Assistant U.S. Attorney California State Bar No. 231929 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-5482; Facsimile: (619) 235-2757 [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07CR3100-JAH DATE: May 12, 2008 TIME: 11:30 a.m. Before Honorable John A. Houston GOVERNMENT'S NOTICE OF MOTION AND MOTIONS IN LIMINE TO: (A) (B) (C) (D) (E) (F) (G) (H) ADMIT A-FILE DOCUMENTS; PROHIBIT COLLATERAL ATTACK OF THE DEPORTATION; ADMIT DEFENDANT'S PRIOR ADMISSIONS; ADMIT RULE 609 EVIDENCE; ADMIT GOVERNMENT'S EXPERT TESTIMONY; PRECLUDE ARGUMENT OF DURESS OR NECESSITY; EXCLUDE WITNESSES EXCEPT CASE AGENT; RENEWED MOTION FOR RECIPROCAL DISCOVERY;

UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 ANTONIO DE LEON-ARTEAGA, 14 Defendant. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO:

NOTICE OF MOTION ERICA ZUNKEL, Counsel for DEFENDANT ANTONIO DE LEON-ARTEAGA PLEASE TAKE NOTICE that on May 12, 2008, at 11:30 a.m., or as soon thereafter as counsel may be heard, the Plaintiff, the UNITED STATES OF AMERICA, by and through its counsel, KAREN P. HEWITT, United States Attorney, and NICOLE ACTON JONES, Assistant United States Attorney, will ask this Court to issue an order granting the following motions in limine. //

Case 3:07-cr-03100-JAH

Document 24

Filed 04/28/2008

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MOTIONS The United States asks the Court pursuant to the United States Constitution, Federal Rules of Criminal Procedure 12, 16, and 26, the Federal Rules of Evidence, and all other applicable statutes, case law and local rules for an order granting the Government's motions in limine to: (A) (B) (C) (D) (E) (F) (G) (H) ADMIT A-FILE DOCUMENTS; PROHIBIT COLLATERAL ATTACK OF THE DEPORTATION; ADMIT DEFENDANT'S PRIOR ADMISSIONS; ADMIT RULE 609 EVIDENCE; ADMIT GOVERNMENT'S EXPERT TESTIMONY; ARGUMENT OF DURESS OR NECESSITY; EXCLUDE WITNESSES EXCEPT CASE AGENT; RENEWED MOTION FOR RECIPROCAL DISCOVERY;

These motions in limine are based upon the instant notice of motion and motions, the attached statement of facts and memorandum of points and authorities, the files and records in the abovecaptioned matter, and any and all other materials that may come to this Court's attention prior to or during the hearing of these motions.

Respectfully submitted, KAREN P. HEWITT United States Attorney /s/ Nicole Acton Jones NICOLE ACTON JONES Assistant U.S. Attorney

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07CR3100-JAH