Free Motion for Order - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 1904

Filed 09/11/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 1:00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM CONCEPCION SABLAN, Defendant. ________________________________________________________________________ William Sablan's Motion For Order Directing The Government To Provide The Court With The Documents, Tapes, And Trial Transcripts Noted In Its Amended Proffer In Advance Of The November 6, 2006 Hearing ________________________________________________________________________ William Sablan, through undersigned court-appointed counsel, respectfully requests the Court to order the government to provide the Court with the exhibits it hopes to introduce at the penalty phase, particularly copies of the audiotapes from CNMI Superior Court Case No. 96-235, as well as the transcripts prepared therefrom, and the videotapes of the use-of-force teams relating to incidents # 7 and # 10 in advance of the November 6, 2006 hearing. As grounds, counsel state: 1. To assist in making the November 6, 2006, hearing as productive as possible, the defense requests that the Court order the government to provide the Court with the exhibits it hopes to introduce at the penalty phase, particularly copies of the audiotapes, transcripts, and videotapes mentioned in its Amended Proffer filed on August 28, 2006. 2. This will enable the Court to have more than a month to review them and be
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Case 1:00-cr-00531-WYD

Document 1904

Filed 09/11/2006

Page 2 of 3

familiar with their contents by the time of the hearing, so a ruling need not be delayed. After all, the November 6th hearing is only ten weeks before the trial, and the Court has stated that it wants to review this evidence in conjunction with ruling on the relevance and reliability of the government's proffered evidence. 3. The defense will make copies for the Court if necessary, but it is more appropriate for the government to bear the expense. Dated: September 11, 2006 Respectfully submitted, Patrick J. Burke Patrick J. Burke P.C. 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 By: s/ Susan L. Foreman Susan L. Foreman 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 Counsel for William Sablan CERTIFICATE OF SERVICE I hereby certify that on September 11, 2006, I electronically filed the foregoing William Sablan's Motion For Order Directing The Government To Provide The Court With The Documents, Tapes, And Trial Transcripts Noted In Its Amended Proffer In Advance Of The November 8, 2006 Hearing with the Clerk of the Court using the CM/EFC system which will send notification of such filing to the following e-mail addresses: [email protected]
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Nathan Chambers Chambers, Dansky & Mulvahill 1601 Blake Street, Suite 300 Denver, CO 80202 303-825-2222

Case 1:00-cr-00531-WYD

Document 1904

Filed 09/11/2006

Page 3 of 3

[email protected] [email protected] [email protected] By: /s/ Susan L. Foreman

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