Not sure this is the right thread to put this on but it does have to do with asking for more funds.
Did Baez or Mason respond to the JAC about their motion that was filed on December 28, 2010. If they did not then I can hear CJPerry stating this at the hearing. jmo
So many times in everyone of the defense motions state:
10/25/2010
http://www.docstoc.com/docs/58593417/10252010-Motion-for-Additional-Hours-of-Investigation
5) Thus the Defense is respectfully requesting an additional 300 hours for services render in-state in
order to continue investigating the evidence alleged in the State’s discovery which continues to be ongoing.
12/13/2010
http://www.docstoc.com/docs/6668980...-Motion-for-Additional-Hours-of-Investigation
4) Thus the Defense is respectfully requesting an additional 300 hours for services render in-state in
order to continue investigating the evidence alleged in the State’s discovery which continues to be ongoing.
01/20/2011
http://www.wesh.com/pdf/26557886/detail.html
15) Therefore in the interest of judicial economy, and trial begins less than 4 months away, the Defense is respectfully requesting an additional 300 hours for in-state investigative services to include the 106.2 hours and
continued investigation of the State’s discovery, which as illustrated above, continues to be on-going until further notice by this court.
Just like the last hearing CJPerry told the defense that they latest discovery was of rebuttal witnesses for the deposition of one of the defense witness. IMO it should fall flat. The defense may have cut their State tax payers funds for their fishing. And why did they not get the hint about new civil lawyers looking for new cases to get JAC funds returned to them by criminal defense attorneys. :banghead:
Excellent analysis!
The State had until
October 31, 2010 to add witnesses to their List.
The State only added (13) new witnesses, past that deadline, with good cause.
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January 14, 2011 - with "good cause" - the State added (1) new witness -
U.S. Secret Service Joseph Stephens, because the State had only just received the Report from the FBI on Jan 13, 2011.
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December 16, 2010 - with "good cause" - the State added (11) new witnesses, who were
TES searchers, to rebut the deposition testimony of Laura B.
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Sept 30, 2010 - still within the Oct 31st deadline - the State added the
President of Blue Star, to testify about issues (about chloroform) that were raised in the depositions of the Medical Examiners and Dr. Vass from Oak Ridge Lab.
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August 30, 2010 - still within the Oct 31st deadline (11) of the new witnesses, who are from
Orange County Corrections (jail), were added to give testimony related to the
Internal Affairs investigation of former jail guard Sylvia H., who allowed access between Inmate Anthony and Inmate Robyn.
The Defense has had plenty of time, since May 7, 2010, to "investigate" and depose the (40)-plus witnesses the State added to their Witness List. The Defense was given until December 31, 2010 to complete all depositions of the "late filed - after May 24, 2010" witnesses on the State Witness List.
The Defense has been aware of the new State witnesses since the day the State filed their "Supplemental Witness Lists" (after May 7, 2010). The Defense does not need more investigative hours to "investigate" these witnesses, now. It should have been done, and the witnesses who the Defense wanted to depose, should have already been deposed by December 31, 2010.
- May 24, 2010 - Supplemental List - (45) new witnesses
- August 10, 2010 Supplemental List - (6) new witnesses (OCSO and K9 and trunk
liner)
- August 30, 2010 Supplemental List - (13) new witnesses (Int Affairs inv and
MySpace and AT&T and ShurTape)
- August 31, 2010 Supplemental List - (14) new witnesses (Custodians of records)
- December 16, 2010 Supplemental List - (11) new witnesses (rebut Laura B)
- January 14, 2011 Supplemental List - (1) new witness (US Secret Service)