USA v. Bonds

Filing 187

WITNESS LIST by Barry Lamar Bonds (Attachments: # 1 Exhibit Swerdloff CV)(Ruby, Allen) (Filed on 10/15/2010)

USA v. Bonds

Doc. 187

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

ALLEN RUBY, SB #47109 LAW OFFICES OF ALLEN RUBY 125 South Market Street, Suite 1001 San Jose, CA 95113-2379 Telephone: [phone] Facsimile: 408-998-8503 CRISTINA C. ARGUEDAS, SB #87787 TED W. CASSMAN, SB #98932 ARGUEDAS, CASSMAN & HEADLEY, LLP 803 Hearst Avenue Berkeley, CA 94710 Telephone: [phone] Facsimile: 510-845-3003 DENNIS P. RIORDAN, SB # 69320 DONALD M. HORGAN, SB #121547 RIORDAN & HORGAN 523 Octavia Street San Francisco, CA 94102 Telephone: [phone] Facsimile: 415-552-2703 Attorneys for Defendant BARRY BONDS

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA, Plaintiffs, vs.
BARRY LAMAR BONDS,

Defendants

) ) ) ) ) ) ) ) ) )

Case No.: CR 07-0732 SI DEFENDANT'S WITNESS LIST Trial Date: March 21, 2011 Hon: Susan Illston

Pursuant to the Court's Order for Pretrial Preparation, Defendant Barry L. Bonds respectfully submits a partial list of witnesses who may be called by the defense at trial. Mr. Bonds previously filed a Witness List on February 13, 2009. Thereafter on
Defendant's Witness List

1
Dockets.Justia.com

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

February 19, 2009, the Court issued its Order Re: Defendant's Motions In Limine ("the February 19, 2009 Order"). In light of the February 19, 2009 Order, Defendant has not listed witnesses whose testimony would relate to evidence which the Court has excluded. 1. Harvey Shields. Mr. Shields was a trainer for Mr. Bonds. If called as a

witness, Mr. Shields may testify to his personal interactions with Mr. Bonds, Greg Anderson, and other potential Government witnesses. 2. Mark Letendre. Mr. Letendre was a trainer for the San Francisco Giants. If

called as a witness, Mr. Letendre may be asked about his personal interactions with Mr. Bonds, Greg Anderson, and other potential Government witnesses. 3. Michael Rains. Mr. Rains is an attorney. If called as a witness he may testify

to promises and representations made by the Government prior to Mr. Bonds' Grand Jury testimony, as well as interactions between the Government and Mr. Bonds after the promises and representations were made, but before he testified. 4. Dr. Ronald Swerdloff. Dr. Swerdloff is a medical doctor specializing in

endocrinology, internal medicine and andrology. As the Director, Harbor-UCLA Reproductive Program ­ World Health Organization Collaborative Center for Reproduction, he has extensive experience in the study and treatment of pituitary gland, including human growth hormone replacement therapy. He is a renowned expert in fields of research regarding effects of exogenous consumption of testosterone and other androgens (steroids), as well as of grown hormone. He has testified as a medical expert in numerous court matters. A copy of his curriculum vitae is attached. Dr. Swerdloff may testify to his opinions concerning the likely effects of anabolic steroids and human growth hormone, as established by peer review studies and reliable scientific methods and procedures. 5. The individuals listed below are all law enforcement agents who, among other

things, conducted interviews of individuals who may be Government witnesses. If such persons give testimony which is subject to impeachment by their prior statements, the individuals listed below may be called to testify to the prior statements: Jeff Novitzky
Defendant's Witness List

2

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
1

Ken Bonano Erwin Rogers Jon Colombet Ed Barberini Christopher Fuelling Brian Cook Heather Young Anthony Montero Douglass Doss John Posusney Steve Coffin Vincent Browning Gregory Jenkins This list does not include all potential defense witnesses. In the judgment of counsel, listing all such witnesses ­ for example, impeachment witnesses ­ would be inconsistent with the Defendant's right to an effective defense.1 Such a list could provide the Government with insight into the defense assessment of weaknesses in the Government's case. It would alert Government witnesses to likely areas of cross-examination, and it would provide untruthful Government witnesses ­ if there are any ­ with advance warning of conversations, relationships and transactions to which impeaching evidence which is and is not available for presentation at trial. Respectfully submitted, DATED: October 15, 2010 LAW OFFICES OF ALLEN RUBY ________/s/______________________ Allen Ruby, Attorney for Defendant Bonds,

A number of impeaching witnesses unavoidably had to be identified on this Witness List because they are law enforcement agents who will probably be subpoenaed through the Government.

Defendant's Witness List

3

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

DATED: October 15, 2010

ARGUEDAS, CASSMAN & HEADLEY, LLP ___________/s/___________________ Cristina A. Arguedas, Attorney for Defendant Bonds,

Defendant's Witness List

4