Free Other Notice - District Court of Arizona - Arizona

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LAW OFFICES OF MICHAEL J. BRESNEHAN, P.C. Michael J. Bresnehan, Esquire 1761 East McNair Drive, Suite 101 Tempe, AZ 85283-5002 480-345-7032 [email protected] State Bar No.: 009415 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, Plaintiff, vs. KINDY JONAGAN, Defendant.

Case No.: CR-04-00820-006-PHX-FJM

DEFENDANT KINDY JONAGAN'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

COMES NOW the defendant, Kindy Jonagan, by and through undersigned attorney, and hereby gives notice that she intends to introduce at trial expert testimony on the following topics: 1. 2. 3. Rebuttal testimony as to automatic clearinghouse electronic funds transfer; Rebuttal testimony as to financial analysis of the companies; Rebuttal testimony as to telemarketing. To the extent that the government is allowed to introduce testimony as to telemarketing, Kindy Jonagan reserves and discloses that she will present expert testimony as to telemarketing. This is not a waiver of any of the rights of Kindy Jonagan to preclude federal agents from attempting to bolster their testimony under the guise of experts.

Case 2:04-cr-00820-FJM

Document 153

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Filed 10/03/2005

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4.

Kindy Jonagan reserves the right to designate the expert once the government identifies the basis for its testimony and the opinions which will be used in this trial. The government does not object to a supplemental disclose at a later date.

RESPECTFULLY SUBMITTED, this 3rd day of October, 2005. MICHAEL J. BRESNEHAN, P.C.

s/ Michael J. Bresnehan Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on this date, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Bruce Blumberg, Rachel Hernandez, Gary Restaino, Jeanette Alvardo, Thomas Hoidal, Ivan Mathew, Gregory Parzych and the Honorable Frederick Martone. I hereby certify that on October 4, 2005, I served a courtesy copy of the attached document by COURIER SERVICE on the following: Honorable Frederick J. Martone. s/ Michael J. Bresnehan

Case 2:04-cr-00820-FJM

Document 153

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Filed 10/03/2005

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