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

Case 3:08-cr-00719-L

Document 19

Filed 08/11/2008

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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 UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR0719-L DATE: August 25, 2008 TIME: 10:00 a.m. Before Honorable M. James Lorenz GOVERNMENT'S NOTICE OF MOTION AND MOTIONS IN LIMINE TO: (A) (B) (C) (D) (E) (F) (G) ADMIT A-FILE DOCUMENTS; PROHIBIT COLLATERAL ATTACK OF THE DEPORTATION; ADMIT DEFENDANT'S PRIOR STATEMENTS; ADMIT RULE 609 EVIDENCE; ADMIT GOVERNMENT'S EXPERT TESTIMONY; PRECLUDE EXPERT TESTIMONY BY DEFENSE; EXCLUDE WITNESSES EXCEPT CASE AGENT;

10 Plaintiff, 11 v. 12 RIGOBERTO HERNANDEZ-RIVERA, 13 Defendant. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO:

AND RENEWED MOTION FOR RECIPROCAL DISCOVERY;

NOTICE OF MOTION JENNIFER COON, Counsel for DEFENDANT RIGOBERTO HERNANDEZ-RIVERA PLEASE TAKE NOTICE that on August 25, 2008, at 10:00 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 3:08-cr-00719-L

Document 19

Filed 08/11/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: August 11, 2008.

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; PRECLUDE EXPERT TESTIMONY BY DEFENSE; 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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08CR0719-L