Free Motion to Exclude Witnesses - District Court of California - California

Case 3:07-cr-03106-BEN

Document 28

Filed 04/03/2008

Page 1 of 2

1 2 3 4 5 6 7 8

KAREN P. HEWITT United States Attorney MICHELLE M. PETTIT Assistant U.S. Attorney California State Bar No. 253406 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7450 Fax: (619) 235-2757 Email: [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT

9 SOUTHERN DISTRICT OF CALIFORNIA 10 UNITED STATES OF AMERICA, 11 Plaintiff, 12 v. 13 MARIA VASQUEZ, 14 Defendant. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO: LEILA W. MORGAN, ESQ., COUNSEL FOR DEFENDANT PLEASE TAKE NOTICE that on April 7, 2008, at 2:00 p.m., or as soon thereafter as counsel may be heard, the plaintiff, UNITED STATES OF AMERICA, by and through its counsel, Karen P. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 07CR3106-BEN Honorable Roger T. Benitez Hearing: April 7, 2008 Time: 2:00 p.m. PLAINTIFF UNITED STATES' NOTICE OF MOTIONS AND MOTIONS IN LIMINE TO: (A) (B) (C) ADMIT "OTHER ACTS" EVIDENCE UNDER RULE 404(B); EXCLUDE ALL WITNESSES EXCEPT CASE AGENT; PROHIBIT EVIDENCE AND ARGUMENT RELATED TO AGE, FINANCES, EDUCATION, HEALTH, AND PUNISHMENT; PRECLUDE SELF-SERVING HEARSAY; PRECLUDE CHARACTER EVIDENCE; PRECLUDE EVIDENCE OF DURESS AND NECESSITY; PRODUCE RECIPROCAL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS.

(D) (E) (F) (G) (H)

Case 3:07-cr-03106-BEN

Document 28

Filed 04/03/2008

Page 2 of 2

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

Hewitt, United States Attorney, and Michelle M. Pettit, Assistant United States Attorney, will ask this Court to enter an order granting the following motions. MOTIONS The plaintiff, UNITED STATES OF AMERICA, by and through its counsel, Karen P. Hewitt, United States Attorney, and Michelle M. Pettit, Assistant United States Attorney, pursuant to the Federal Rules of Criminal Procedure, and all other applicable statutes, case law and local rules, hereby moves this Court for an order granting the following motions: (A) (B) (C) (D) (E) (F) (G) (H) ADMIT "OTHER ACTS" EVIDENCE UNDER RULE 404(B); EXCLUDE ALL WITNESSES EXCEPT CASE AGENT; PROHIBIT EVIDENCE AND ARGUMENT RELATED TO AGE, FINANCES, EDUCATION, HEALTH, AND PUNISHMENT; PRECLUDE SELF-SERVING HEARSAY; PRECLUDE CHARACTER EVIDENCE; PRECLUDE EVIDENCE OF DURESS AND NECESSITY; PRODUCE RECIPROCAL DISCOVERY; AND GRANT LEAVE TO FILE FURTHER MOTIONS. These motions are based upon the notice of motions and are supported by the attached statement of facts and memorandum of points and authorities.

DATED: April 1, 2008

Respectfully Submitted, KAREN P. HEWITT United States Attorney /s/ Michelle M. Pettit MICHELLE M. PETTIT Assistant U.S. Attorney

2

07CR3106-BEN