Case 3:08-cr-00802-JAH
Document 25
Filed 06/06/2008
Page 1 of 2
1 DAVID M.C. PETERSON California State Bar Number 254498 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, California 92101-5008 Tel: (619) 234-8467 / Fax: (619) 687-2666 4 [email protected] 5 Attorneys for Mr. Fernandez 6 7 8 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE JOHN A. HOUSTON) ) ) ) ) ) ) ) ) ) ) Case No.: 08cr0802-JAH Date: Time: June 13, 2008 8:30 a.m.
10 UNITED STATES OF AMERICA, 11 12 v. 13 JOSE JUAN FERNANDEZ, 14 Defendant. 15 ____________________________________ 16 TO: 17 Plaintiff,
NOTICE OF MOTIONS AND MOTIONS IN LIMINE TO EXCLUDE THE GOVERNMENT'S PROPOSED "EXPERT" TESTIMONY
KAREN HEWITT, UNITED STATES ATTORNEY, and PAUL STARITA, ASSISTANT UNITED STATES ATTORNEY PLEASE TAKE NOTICE that, on June 13, 2008, at 8:30 a.m., or as soon thereafter as
18 counsel may be heard, the accused, Jose Juan Fernandez, by and through his attorneys, David Peterson, 19 Steven Barth, and Federal Defenders of San Diego, Inc., will ask this Court to enter an order granting the 20 motions outlined below. 21 MOTIONS 22 Mr. Jose Juan Fernandez, by and through his counsel, David Peterson, Steven Barth, and 23 Federal Defenders of San Diego, Inc., brings these motions in limine and other trial motions to: 24 Exclude the Government's Proposed "Expert" Testimony. 25 Mr. Fernandez brings this motion pursuant to the Fourth, Fifth and Sixth Amendments to 26 the United States Constitution, Fed. R. Crim. P. 12, 16 and 26, and all other applicable statutes, case law 27 and local rules. This motion is based on the accompanying statement of facts and memorandum of points 28 and authorities.
Case 3:08-cr-00802-JAH
Document 25
Filed 06/06/2008
Page 2 of 2
1 2 3 Dated: June 6, 2008 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
Respectfully submitted, s/ David M.C. Peterson DAVID M.C. PETERSON Federal Defenders of San Diego, Inc. Attorneys for Mr. Fernandez [email protected]