USA v. Bonds

Filing 91

Letter from M. PARRELLA, J. NEDROW, J. FINIGAN, D. WILSON to Honorable Susan Illston as to Barry Lamar Bonds (Finigan, Jeffrey) (Filed on 1/28/2009)

USA v. Bonds

Doc. 91

U.S. Department of Justice United States Attorney Northern District of California

11th Floor, Federal Building 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102

[phone] FAX:[phone]

January 28, 2009

EFILED & HAND DELIVERED TO COURT Honorable Susan Illston United States District Court Judge 450 Golden Gate Avenue, 19th Floor San Francisco, CA 94102 Re: United States v. Barry Bonds CR 07-0732 SI Dear Judge Illston, We write to inform the Court of the government's intention to publicly file its response to the defendant's motion in limine. As the Court is aware, the government's response to the defendant's January 15, 2009 motion in limine is due tomorrow, January 29, 2009. The defendant requested an order from the Court authorizing the filing of the exhibits to their motion under seal, and the government opposed that request. The government maintains that there is no factual or legal basis for filing any portion of the defendant's motion or the government's response under seal. The Court has not yet ruled on how the defense exhibits should be filed. In light of the above, the government respectfully requests a ruling from the Court related to the motion to seal before the government must file its response tomorrow. Without a ruling

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from the Court, the government's position is that it is required by law and Department of Justice Guidelines to file its response publicly.

Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney

___________/s/_________________ MATTHEW A. PARRELLA JEFFREY D. NEDROW JEFFREY R. FINIGAN J. DOUGLAS WILSON Assistant United States Attorneys

cc:

Allen Ruby, Esq. (Via facsimile) Dennis Riordan, Esq. (Via facsimile)