Free Other Notice - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona MARY BETH PFISTER Assistant U.S. Attorney Arizona State Bar No.015103 Two Renaissance Square 40 North Central Avenue Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 [email protected] JOHN BOYLE Assistant U.S. Attorney Arizona State Bar No. 015640

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America
CR-04-1281-PHX-DGC

Plaintiff, v. Michael Anderson and Gina Anderson, Defendants. GOVERNMENT'S NOTICE OF INTENT TO RELY UPON EVIDENCE PURSUANT TO RULE 702, FEDERAL RULES OF EVIDENCE

The United States, by and through counsel undersigned, hereby provides notice that it intends to introduce certain evidence pursuant to Federal Rules of Evidence, Rule 702, at the trial of this matter. First, if defendants will not stipulate that the signatures appearing on their tax returns for the years 2000 and 2001 are their signatures, the government intends to call Sandra Ramsey Lines as an expert witness pursuant to Rule 702 to testify regarding her handwriting analysis of known writing samples of defendants and certain other documents the government will offer as writings by defendants (including defendants' tax returns). Specifically, Ms. Lines will testify regarding whether the questioned writings all were made by the same person. The government has provided counsel for the defendants with Ms. Lines's CV and will provide defendants with a copy of any reports by Ms. Lines if there is no stipulation. 1

Case 2:04-cr-01281-DGC

Document 95

Filed 02/22/2006

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The government also intends to call Drug Enforcement Administration Special Agent

2 Jamie Callahan to testify regarding the value of the drugs at issue. Specifically, Special Agent 3 Callahan will testify regarding the price of marijuana and cocaine in the area of Yuma, Arizona 4 at the time of defendant's criminal activity. This testimony will explain how the amount of 5 money defendant received for waiving through loads of these drugs indicates the minimum 6 quantity of drugs he waived through. The testimony will also corroborate the government's 7 cooperating witnesses testimony regarding the quantity of drugs waived through the Port of 8 Entry. The government will provide defendants with a copy of Special Agent Callahan's CV 9 before trial. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 S/ Mary Beth Pfister MARY BETH PFISTER Assistant U.S. Attorney Respectfully submitted this 22nd day of February, 2006. PAUL K. CHARLTON United States Attorney District of Arizona

Case 2:04-cr-01281-DGC

Document 95

Filed 02/22/2006

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CERTIFICATE OF SERVICE

I hereby certify that on February 22, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: David Lockhart Attorney for Michael Anderson Patricia Gitre Attorney for Gina Anderson s/Raquel Lopez

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Case 2:04-cr-01281-DGC

Document 95

Filed 02/22/2006

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