Free Response to Motion - District Court of Colorado - Colorado

Case 1:00-cr-00310-WYD

Document 427

Filed 05/16/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 00-cr-00310-WYD-04

UNITED STATES OF AMERICA, Plaintiff, v. 4. RICARDO GONZALEZ, Defendant.

GOVERNMENT'S CONSOLIDATED RESPONSE TO DEFENDANTS' PRE-TRIAL MOTIONS: MOTION FOR UNOPPOSED MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE MOTIONS (Document Number 424); MOTION FOR PRESERVATION OF RECORDINGS AND NOTES (Document Number 425); and REQUEST FOR NOTICE OF INTENT TO CALL EXPERT WITNESSES AND DISCOVERY PURSUANT TO RULE 16(a)(1)(D) AND (E), Fed. R. Crim. P. (Document Number 426)

The United States of America, by and through its undersigned Assistant United States Attorney for the District of Colorado, hereby responds to the above captioned motions showing unto the Court as follows: 1. In response to the first motion, Document Number 424, and as stated in

that motion, the Government has no objection to the relief requested therein.

Case 1:00-cr-00310-WYD

Document 427

Filed 05/16/2007

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2.

In response to the second motion, Document Number 425, the

Government does not believe that there are any recordings. With respect to the requested preservation of notes, due to the age of the case, a 2000 indictment, the Government is certain that all notes, if any, have been converted to reports by the various agents assigned to this investigation. Copies of these reports have been served in the 6,088 pages of discovery served to date in this matter. 3. In response to the third motion, Document Number 426, the Government

has served copies of the DEA laboratory reports with respect to the analyses of the controlled substances in this case in the referenced pre-trial discovery. The only expert witness identified by the Government at this time is the forensic chemist or chemists who conducted the analyses of these controlled substances. The Government will provide a Rule 16 summary of the analyses well prior to trial and a curriculum vitae for the expert witness(es) identified above. Respectfully submitted this 16th day of May, 2007. TROY A. EID United States Attorney

By: s/ James R. Boma JAMES R. BOMA Assistant United States Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 FAX: (303) 454-0401 E-mail: [email protected] Attorney for Government

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Case 1:00-cr-00310-WYD

Document 427

Filed 05/16/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on this 16 day of May, 2007, I electronically filed the foregoing GOVERNMENT'S CONSOLIDATED RESPONSE TO DEFENDANTS' PRE-TRIAL MOTIONS: MOTION FOR UNOPPOSED MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE MOTIONS (Document Number 424);
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MOTION FOR PRESERVATION OF RECORDINGS AND NOTES (Document Number 425); and REQUEST FOR NOTICE OF INTENT TO CALL EXPERT WITNESSES AND DISCOVERY PURSUANT TO RULE 16(a)(1)(D) AND (E), Fed. R. Crim. P. (Document Number 426) with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Mitchell Baker [email protected],[email protected] Richard James Banta [email protected],[email protected] J. Michael Dowling [email protected] Dennis W. Hartley [email protected] Neil E. MacFarlane [email protected] John F. Sullivan , III [email protected] and I hereby certify that I have mailed or served the document or paper to the following non-CM/ECF participants in the manner indicated: s/Lisa Vargas LISA VARGAS Legal Assistant to James R. Boma Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0409 E-mail: [email protected]

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