USA v. Bonds

Filing 133

REPLY TO RESPONSE to Motion by Barry Lamar Bonds re 128 Response to Motion, Supplemental Memorandum Re Admissibility of Government's Proffered Expert Testimony (Attachments: # 1 Exhibit A - Goodman & Gilman, # 2 Exhibit B - Declaration of Dr. Ronald S. Swerdloff, MD, # 3 Exhibit C - Curriculum Vitae of Dr. Ronald S. Swerdloff, MD)(Cassman, Ted) (Filed on 2/18/2009)

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1 2 3 4 5 6 7 8 9 10 JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney BRIAN J. STRETCH (CSBN 163973) Chief, Criminal Division MATTHEW A. PARRELLA (NYSBN 2040855) JEFFREY D. NEDROW (CASBN 161299) JEFFREY R. FINIGAN (CASBN 168285) J. DOUGLAS WILSON (DCBN 412811) Assistant United States Attorneys 450 Golden Gate Avenue San Francisco, California 94102 Telephone: (415) 436-7232 Facsimile: (415) 436-7234 Email: jeffrey.finigan@usdoj.gov Attorneys for Plaintiff 11 12 13 14 15 UNITED STATES OF AMERICA, 16 Plaintiff, 17 v. 18 BARRY LAMAR BONDS, 19 Defendant. 20 21 22 23 24 25 26 27 28 The government respectfully submits this First Amended set of proposed jury instructions. The amendments are as follows. First, Model instruction 3.16 (corruptly) has been deleted, because that term is defined within Special Instruction #1. Second, Model instruction 4.3 (other crimes, wrong, or acts of defendant) has been deleted and replaced with Special Instructions #2 and #3, which fit the facts of this case better than the model instruction. Leave is respectfully requested to include such other additional instructions as may become appropriate FIRST AMENDED PROPOSED INSTRUCTIONS CR 07-0732 SI UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) ) ) ) ) ) ) ) No. CR 07-0732 SI FIRST AMENDED PROPOSED JURY INSTRUCTIONS Trial: Time: Court: March 2, 2009 8:30 a.m. Hon. Susan Illston 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 during the course of the trial. A copy of these proposed instructions will be delivered to the Court on a 3 " floppy disk in the WordPerfect 9 format. Depending on the evidence adduced at trial, some of the instructions included herein may not be appropriate, and some additional instructions may be required. The government respectfully reserve the right to request additional jury instructions or modifications of the attached instructions at trial. DATED: February 18, 2009 Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney ____________/s/____________________ M A T T H E W A. PARRELLA J E F F R E Y D. NEDROW J E F F R E Y R. FINIGAN J. DOUGLAS WILSON Assistant United States Attorneys FIRST AMENDED PROPOSED INSTRUCTIONS 2 CR 07-0732 SI 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 10 11 12 13 14 15 16 4.17 5.6 7.6 8.112 8 9 4.1 4.9 NO. 1 2 3 4 5 6 7 TABLE OF JURY INSTRUCTIONS NINTH CIRCUIT MODEL JURY INSTRUCTIONS 1.12 2.2 2.3 2.4 2.5 2.7 3.12 DESCRIPTION OUTLINE OF TRIAL BENCH CONFERENCES AND RECESSES STIPULATED TESTIMONY STIPULATIONS OF FACT JUDICIAL NOTICE TRANSCRIPT OF RECORDING IN ENGLISH SEPARATE CONSIDERATION OF MULTIPLE COUNTS STATEMENTS BY DEFENDANT TESTIMONY OF WITNESSES INVOLVING SPECIAL CIRCUMSTANCES IMMUNITY, BENEFITS, ACCOMPLICE, PLEA OPINION EVIDENCE, EXPERT WITNESS KNOWINGLY COMMUNICATION WITH COURT FALSE DECLARATION BEFORE GRAND JURY OBSTRUCTION OF JUSTICE ACTIVITIES NOT CHARGED EVIDENCE OF OTHER ACTS OF DEFENDANT OR ACTS AND STATEMENTS OF OTHERS Special #1 Special #2 Special #3 FIRST AMENDED PROPOSED INSTRUCTIONS 3 CR 07-0732 SI

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