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    United States District Court For The District

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    dvanmeter
    This document is a statement for purposes of a pretrial conference filed by the defense attorney for Cirino Gonzalez. It identifies 5 potential issues for the pretrial conference: 1) the admissibility of co-conspirator statements made after Gonzalez left the residence, 2) the admissibility of statements made by co-defendants in custody or to law enforcement, 3) the admissibility of weapons not linked to the defendant, 4) procedural issues with the co-defendant representing himself, and 5) that this statement only identifies preliminary issues for the pretrial conference. The attorney certifies providing a copy of the statement to the prosecution and co-defendant.

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    United States District Court For The District

    Uploaded by

    dvanmeter
    25 views2 pages
    This document is a statement for purposes of a pretrial conference filed by the defense attorney for Cirino Gonzalez. It identifies 5 potential issues for the pretrial conference: 1) the admissibility of co-conspirator statements made after Gonzalez left the residence, 2) the admissibility of statements made by co-defendants in custody or to law enforcement, 3) the admissibility of weapons not linked to the defendant, 4) procedural issues with the co-defendant representing himself, and 5) that this statement only identifies preliminary issues for the pretrial conference. The attorney certifies providing a copy of the statement to the prosecution and co-defendant.

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    United States District Court for the District

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    This document is a statement for purposes of a pretrial conference filed by the defense attorney for Cirino Gonzalez. It identifies 5 potential issues for the pretrial conference: 1) the admissibility of co-conspirator statements made after Gonzalez left the residence, 2) the admissibility of statements made by co-defendants in custody or to law enforcement, 3) the admissibility of weapons not linked to the defendant, 4) procedural issues with the co-defendant representing himself, and 5) that this statement only identifies preliminary issues for the pretrial conference. The attorney certifies providing a copy of the statement to the prosecution and co-defendant.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    25 views2 pages

    United States District Court For The District

    Uploaded by

    dvanmeter
    This document is a statement for purposes of a pretrial conference filed by the defense attorney for Cirino Gonzalez. It identifies 5 potential issues for the pretrial conference: 1) the admissibility of co-conspirator statements made after Gonzalez left the residence, 2) the admissibility of statements made by co-defendants in custody or to law enforcement, 3) the admissibility of weapons not linked to the defendant, 4) procedural issues with the co-defendant representing himself, and 5) that this statement only identifies preliminary issues for the pretrial conference. The attorney certifies providing a copy of the statement to the prosecution and co-defendant.

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    UNITED STATES DISTRICT COURT

    FOR THE
    DISTRICT OF NEW HAMPSHIRE

    *************************
    * *
    * UNITED STATES OF AMERICA*
    * *
    * v. * 07-CR-189
    * *
    * CIRINO GONZALEZ *
    * *
    *************************

    STATEMENT FOR PURPOSES OF PRETRIAL

    NOW COMES the defendant, Cirino Gonzalez, by counsel, David H. Bownes, and

    respectfully identifies potential issues with respect to trial in the above-captioned matters.

    1. The Admissibility “Co-conspirator’s Statements” after Mr. Gonzalez left the Brown

    residence in June of 2007. US v. Serrano, 870 F.2d 1 (1st Cir. 1989).

    2. The admissibility of the statements made by the co-defendants, while in custody, or in

    the alternative made to law enforcement agents. Crawford v. Washington, 1245 S.Ct. 1354

    (2004).

    3. The admissibility of a whole range of weapons and explosive devices that can not be

    linked in any manner to this defendant. The defendant is awaiting forensics.

    4. It is submitted that while Mr. Riley has a right to proceed pro se and has been afforded

    a stand-by counsel, that situation presents procedural and substantive difficulties.

    5. This preliminary pretrial statement is intended to identity only preliminary issues for

    purposes of the pretrial conference currently scheduled for January 8, 2008.


    Respectfully Submitted,
    Cirino Gonzalez,
    By His Attorney,

    LAW OFFICE OF DAVID H. BOWNES, P.C.

    Dated: January 7, 2008 /S/ David H. Bownes, Esq.


    David H. Bownes, Esq.
    NH Bar No.: 277
    486 Union Avenue
    Laconia, NH 03246
    (603) 524-4330
    [email protected]

    CERTIFICATION

    I hereby certify that on this 7th day of January, 2008 that a copy of the foregoing
    Statement for Purposes of Pretrial has been forwarded to Arnold Huftalen, Esq., United States
    Attorney’s Office, Paul Garrity, Esq, and to Stanley Norkunas, Esq. via ECF and to Daniel Riley
    via U.S. First Class mail.

    /S/ David H. Bownes, Esq.


    David H. Bownes, Esq.

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