Free Other Notice - 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 Defendant, Robert Shinn, by and through undersigned counsel, hereby 17 gives notice that he will introduce trial expert testimony on the following topics: 18 1. Rebuttal testimony as to Automatic Clearinghouse Electronic 19 20 21 22 23 24 Funds Transfer. 2. 3. Rebuttal testimony as to Financial Analysis of the Companies. Rebuttal testimony as to Telemarketing, Robert Shinn, reserves vs. Robert Shinn, et al., Defendant. United States of America, Plaintiff, No. CR-04-0820-PHX-FJM DEFENDANT, ROBERT SHINN'S NOTICE OF INTENT TO INTRODUCE EXPERT TESTIMONY PURSUANT TO FED. R. CRIM P. 16(a)(1)(G), RULE 702 OF THE FEDERAL RULES OF EVIDENCE IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

and discloses that he will present expert testimony as to Telemarketing. This is not a waiver of any of the rights of Robert Shinn to preclude Federal Agents from

25 attempting t bolster their testimony under the guise of an expert witness. 26 / / / 27 / / / 28 / / /

Case 2:04-cr-00820-FJM

Document 147

Filed 09/30/2005

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4.

Robert Shinn reserves the right to designate the expert once the

2 Government identifies the basis for its testimony and the opinions which will be used 3 in this trial. The Government does not object to a supplemental disclose at a later 4 date. 5 6 7 8 9 10 11 12 Copy of the foregoing was transmitted by CM/ECF 13 this 30th day of September, 2005, to: 14 RACHEL C. HERNANDEZ and GARY RESTAINO 15 United States Attorney's Office Two Renaissance Square 16 40 N. Central Avenue 17 Suite 1200 Phoenix, Arizona 85004-4408 18 BRUCE E. BLUMBERG, ESQ. 19 MICHAEL J. BESNEHAN, ESQ. 20 THOMAS M. HOIDAL, ESQ. 21 IVAN KURIAN MATHEW, ESQ. 22 23 GREGORY THOMAS PARZYCH 24 Copy mailed to: 25 ROBERT SHINN Defendant 26 27 s/ Jeanette E. Alvarado JEANETTE E. ALVARADO 28
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Respectfully submitted: September 30, 2005. JON M. SANDS Federal Public Defender

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

Case 2:04-cr-00820-FJM

Document 147

Filed 09/30/2005

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