UNITED STATES DISTRICT COURTFOR THEDISTRICT OF NEW HAMPSHIRE* * * * * * * * * * * * * * * * * * * * * * * * **** UNITED STATES OF AMERICA**** v.*07-CR-0189-03-GZS*** CIRINO GONZALEZ**** * * * * * * * * * * * * * * * * * * * * * * * *MOTION IN LIMINE/THE WITNESS ANTHONY DOROTHY
NOW COMES
the defendant, Cirino Gonzalez, by counsel, David H. Bownes, andrespectfully requests that this Court preclude the government from offering the testimony of Anthony Dorothy for any purpose whatsoever.As grounds for this request it is stated:1. By discovery provided to the defendant on or about March 17, 2008 the governmenthas identified Anthony Dorothy as a witness in this matter.2. It is alleged that Mr. Dorothy had conversations with Mr. Riley while Mr. Riley washoused at the Strafford County House of Corrections.3. It is further alleged that Mr. Riley made admissions with respect to the conspiracycharge.4. There is no question that these are not statements made by Mr. Riley in thefurtherance of the conspiracy.5. The admission of any of these statements by Mr. Riley to Mr. Dorothy implicates Mr.Gonzalez in a fundamental way. It is not possible to “sanitize” these statements in a way whichwould only implicate Riley.6. Mr. Dorothy’s testimony as it relates to any statements by Mr. Riley would violate the
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