Free Motion for Joinder - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams Street, Ste. 201 3 Phoenix, Arizona 85007 4 Telephone: (602) 382-2721 5 JEANETTE E. ALVARADO, #016111 Asst. Federal Public Defender 6 Attorney for Defendant 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 COMES NOW, Defendant, Robert Shinn, by and through undersigned counsel, and hereby joins in defendant, John Desiderio's Motion for Disclosure of Agent Personnel Files.. The government has also designated Special Agent, Nora Kollas and Special Agent, Julie Healferty as expert witnesses in this case. (See Exhibit "A" as attached to Richard Nail's Joinder Motion). Disclosure of the personnel files is even vs. Robert Shinn, et al., Defendant. United States of America, Plaintiff, No. CR-04-0820-PHX-FJM JOINDER IN MOTION FOR DISCLOSURE OF AGENT PERSONNEL FILES AND SUPPLEMENTAL MOTION FOR DISCLOSURE OF PERSONNEL FILES OF SPECIAL AGENT, NORA KOLLAS OF THE FEDERAL BUREAU OF INVESTIGATION AND SPECIAL AGENT, JULIE HEALFERTY IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

25 more appropriate since the Government has attempted to designate these two agents 26 as experts witnesses, placing their qualifications to give opinion testimony and issue. 27 F.R.Cr.P. § 16(a) (1)(G). 28 / / / ///

Case 2:04-cr-00820-FJM

Document 148

Filed 09/30/2005

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: September 30, 2005. 4 5 6 7 8 9 Copy of the foregoing transmitted by CM/ECF 10 was 30th day of September, 2005, to: this 11 RACHEL C. HERNANDEZ and 12 GARY RESTAINO United States Attorney's Office 13 Two Renaissance Square 40 N. Central Avenue 14 Suite 1200 Phoenix, Arizona 85004-4408 15 BRUCE E. BLUMBERG, ESQ. 16 17 MICHAEL J. BESNEHAN, ESQ. 18 THOMAS M. HOIDAL, ESQ. 19 IVAN KURIAN MATHEW, ESQ. 20 GREGORY THOMAS PARZYCH 21 Copy mailed to: 22 ROBERT SHINN 23 Defendant 24 26 27 28
\Notice of Joinder DisclosureAgentFile\Kollas\Healferty

JON M. SANDS Federal Public Defender

s/Jeanette E. Alvarado JEANETTE E. ALVARADO Asst. Federal Public Defender

s/ Jeanette E. Alvarado 25 JEANETTE E. ALVARADO

Case 2:04-cr-00820-FJM

Document 148

Filed 09/30/2005

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