01/28/2010 66 MOTION for (404b) Information of defendant or any co-defendant Regarding evidence of independent and separate offenses, wrongs or acts by Rufus Paul Harris. (Manchel, Howard) (Entered: 01/28/2010)
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MOTION FOR PRETRIAL DISCLOSURE OF EVIDENCE OF INDEPENDENT AND SEPARATE OFFENSES, WRONGS, OR ACTS
Comes now RUFUS PAUL HARRIS, by his counsel, and moves the Court to order the Government to disclose prior to trial all evidence of independent and separate offenses, wrongs, or acts which the prosecution may attempt to introduce at trial to show motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident regarding the Defendant’s actions or conduct.
This request is aimed at all crimes, wrongs, or acts not enumerated in the indictment of which the Government has knowledge and Defendant’s relies on Federal Rule of Evidence 404(b) as authority for said request.
WHEREFORE, the Defendant prays that this motion be granted and disclosure be ordered immediately.
Howard J. Manchel
Howard J. Manchel
Ga. Bar No. 468550
729 Piedmont Avenue, NE
Atlanta, Ga. 30308
404-522-1701 |
