Free Motion to Produce - District Court of Connecticut - Connecticut

Case 3:00-cr-00150-JBA Document 50 Filed 09/14/2005 Page 1 of 2 I
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA :
vs. : CRIMINAL NO. 3:00CR150(JBA)
DENISE BARRACKS : September 14, 2005
MOTION FOR PRODUCTION
The defendant respectfully moves the Court to order the United States Probation Office to
produce, in advance of the hearing scheduled for September 21, 2005, the chronological records that
its officers have maintained regarding Denise Barracks during the period from April 1, 2005 through
July 15, 2005. Those dates correspond to the dates of alleged violations contained in the pending Form
12 petition. The disclosure of this requested material is essential to ensure that the revocation hearing
accords the defendant due process of law and an adequate opportunity to confront and cros s-examine
the witnesses against her, pursuant to her Fifth and Sixth Amendment Constitutional rights and in
accordance with Federal Rule of Criminal Procedure 32.1. The defendant has requested this _
information from the probation office, and the probation office has refused to disclose it.
Ir1 support of this motion, the defendant relies upon the attached memorandum of law.
Respectfully submitted,
The Defendant,
Denise Barracks
Thomas G. Dennis
Federal Defender
Dated: September 14, 2005 ji; . / allcW»—- i
Terence S. Ward
Asst. Federal Defender
10 Columbus Blvd, FL 6
Hartford, CT 06106-1976
Bar No. Ct00023
(860) 493-6260
Email: [email protected]

Case 3:00-cr-00150-JBA Document 50 Filed O9/14/2005 Page 2 of 2
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CERTIFICATION
I HEREBY CERTIFY that a copy of the foregoing motion for production has been mailed to
Keith King, Assistant United States Attorney, P.O. Box 1824, New Haven, CT 06508, on this 9 day of
September 2005 and to Jennifer Amato, United States Probation Office, 450 Main Street, Hartford, CT
06103.
Deirdre A. Murray ( 3