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United States of America v. Dustin Bole

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


March 5, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
DUSTIN BOLE,
DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Kendall J. Newman

UNITED STATES' MOTION LEAVE FOR TO FILE RESPONSE MOTION IN TO DEFENDANT'S BRIEF TRIAL

DATE: March 12, 2012 TIME: 9:00 a.m.

MOTION FOR LEAVE TO FILE

The United States, through the undersigned counsel, moves for leave to file two opposition motions responding to objections raised by the Defendant's trial brief (Docket # 25).

At the trial confirmation hearing on February 22, 2012, the Court set March 1, 2012 as the deadline for both parties to file motions in limine and for the Defendant to file his trial brief. March 5, 2012 was set as the deadline to respond to motions in limine. No deadline was set to respond to objections raised in the Defendant's trial brief.

The Defendant's trial brief raises two objections to evidence the Government will seek to introduce. First, "[t]he defense anticipates raising a Crawford" objection to certain Social Security Administration paperwork. Pg. 3, Docket Entry # 25. Second, "[t]he defense will object to some of the anticipated testimony" of the Government's expert. Id.

The Government believes that these objections are best handled pre-trial before a jury has been selected and witnesses called. Therefore, the Government requests leave to file responses to the two objections raised by the Defendant in his trial brief. The government anticipates having its responses ready by the end of business on March 5, 2012.

Dated: March 1, 2012 Respectfully submitted, BENJAMIN B. WAGNER United States Attorney /s/_Nick Fogg NICHOLAS M. FOGG Special Assistant U.S. Attorney /s/ Christopher S. Hales CHRISTOPHER S. HALES Special Assistant U.S. Attorney

FOR GOOD CAUSE SHOWN, THE GOVERNMENT IS GRANTED LEAVE TO FILE RESPONSES TO OBJECTIONS RAISED IN THE DEFENDANT'S TRIAL BRIEF. THOSE RESPONSES ARE DUE BY 5PM ON MARCH 5, 2012.

KENDALL J. NEWMAN UNITED STATES MAGISTRATE JUDGE

20120305

© 1992-2012 VersusLaw Inc.



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