Free Notice of Correction - District Court of Arizona - Arizona

ILED ____ LODGED
1 Noir-Rust; Bond ___ RECEIVED _____ COPY
4132 E. Alan Lane I
2 Phoenix, Arizona 85028 MAR 0 8 2006
3 602'996`0095 CLERK U S DISTRICT COURT
DISTRICT OF ARIZONA
4 BY I ..n. :._
UNITED STATES DISTRICT COURT — DISTRICT OF ARIZONA
5
6 United States of America ) No. CR 03-0974-PHX-DGC
Plaintiff, )
I v. } DEFENSE IVIOTIONS THE COURT TO
Neil Rusty Bond ) ORDER AND COMPEL THE U.S.
8 Defendant, Neil Rusty Bond. ) GOVERNMENT T0 PRODUCE VIDEO
9 ) TAPE OF SEARCH AND SEIZURE OF
) DEFENDANT, NEIL RUSTY BOND’S
10 ) RESIDENCE AND HOME
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I 15 Defendant, Neil Rusty Bond, respectfully moves this Court to order and compel the U.S.
16 Government to produce the videotape of the search and seizure of Defendant, Neil Rusty
1-; Bond’s residence and home, as set forth more fully in the attached Memorandum and
18 Conclusion of this motion.
1 9 E Q
2 O
2 1 Neil Rusty Bond
4132 East Alan Lane
22 Phoenix, AZ 85028
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Case 2:03-cr-00974-DGC Document 189 Filed O3/O8/2006 Page I of 3

2 Memorandum
3 There was a Jury Trial of Defendant, Neil Rusty Bond, based from a Superceding
4 Indictment of Social Security Fraud, with a Loss to the U.S. Government, of $101,222.70
5 (one hundred one thousand two hundred twenty two dollars), and based from an
i Indictment of Theft of Government Property over $1,000.00 (one thousand dollars).
B On March 11, 2005, Defendant, Neil Rusty Bond was found guilty of 2 (two) counts; Social
9 Security Fraud with a Loss to the U.S. Government, of $101,222.70 (one hundred one
10 thousand two hundred twenty two dollars), and Theft of Government Property over
1 1 $1,000.00 (one thousand dollars).
12 Over 100 (one hundred) audiocassette tape recordings were present in the beginning of the
13 search and seizure, on Defendant, Neil Rusty Bond’s bookshelf, located in Defendant, Neil
14 Rusty Bond’s home, and no tapes were present at the end of the search and seizure, on
15 Defendant, Neil Rusty Bond’s bookshelf, located in Defendant, Neil Rusty Bond’s home.
16 The videotape represents the fact that the missing tapes after the search and seizure of
17 Defendant, Neil Rusty Bond, by OIG Agent, Troy Turk, and OIG Agent, Troy Turk
18 denying the existence of the audiocassette tapes, the videotape ofthe search and seizure,
I becomes pertinent evidence regarding the Brady Doctrine and Brady Evidence.
2 1 Conclusigg
2 2 Defendant, Neil Rusty Bond, respectfully motions this Court to order and compel, the U.S.
23 Government to produce the videotape of the search and seizure of Defendant, Neil Rusty
24 Bond’s residence and home.
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Case 2:03-cr-00974-DGC Document 189 Filed O3/O8/2006 Page 2 of 3

1 Foregoing p‘repare¢l for Defendant, Neil Rusty Bond.
2
3 Copy of the foregoing mailed./delivered
4 this & day of fllgck, 2006 to:
5 Michelle Hamilton-Burns
Assistant U.S. Attorney
6 Two Renaissance Square
40 North Centra! Avenue, Suite 1200
7 Phoenix, Arizona 85004-4408
B
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Case 2:03-cr-00974-DGC

Document 189

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