Free Other Notice - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona EMORY T. HURLEY Assistant U.S. Attorney Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 014812 Telephone (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America Plaintiff, v. Antonio Hernandez-Rivera, and Jorge Avena-Pardo, Defendants. The United States, by and through counsel undersigned, provides notice pursuant to Fed. R. Evid. 702, that it intends to introduce at trial expert testimony from Immigration and Customs Enforcement (ICE) Special Agent, Angel Rascon, regarding the operation of alien smuggling and hostage taking activities in the United States. Agent Rascon will testify as to how an alien smuggling organization operates from Mexico to Phoenix, AZ to the alien's final destination including the transportation of aliens, the demand and collection of money from family members and the release of aliens. He will also discuss hostage taking as it applies to aliens being taken from one smuggler to another. Agent Rascon's opinion is based on 17 years of experience as a federal agent investigating immigration offenses. Respectfully submitted this 29 day of November, 2005. PAUL K. CHARLTON United States Attorney District of Arizona S/Emory T. Hurley EMORY T. HURLEY Assistant U.S. Attorney UNITED STATES' NOTICE OF INTENT TO RELY UPON EVIDENCE PURSUANT TO RULE 702, FEDERAL RULES OF EVIDENCE CR-04-872-PHX-DGC

Case 2:04-cr-00872-DGC

Document 64

Filed 11/29/2005

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CERTIFICATE OF SERVICE I hereby certify that on November 29, 2005, 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: Jason Leonard and David Ochoa

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Case 2:04-cr-00872-DGC

Document 64

Filed 11/29/2005

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