Case 2:05-cr JFW Document 2724 Filed 02/14/2007 Page 1 of 5

Similar documents
) NOTICE OF INTENT TO SEEK THE DEATH PENALTY

DONALD SCOTT TAYLOR, is convicted of one or both of the capital offenses relating

Case 4:14-cr JPG Document 92 Filed 04/21/15 Page 1 of 5 Page ID #369 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

Pursuant to the requirements of 18 U.S.C (a) and. that it believes that the circumstances of this case are such

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA GOVERNMENT S NOTICE OF INTENT TO SEEK THE DEATH PENALTY

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION NOTICE OF INTENT TO SEEK THE DEATH PENALTY

Murder of Eric Smith. Pursuant to the requirements of 18 U.S.C. 3593(a), the United States hereby gives notice that it believes that the

FOR THE CENTRAL DISTRICT OF CALIFORNIA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

Case 9:06-cr DTKH Document 311 Entered on FLSD Docket 02/20/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

v. Criminal No [ELECTRONICALLY FILED] JELANI SOLOMON

NOTICE OF INTENT TO SEEKA SENTENCE OF DEATH

Case 2:08-cr wks Document 106 Filed 08/25/2009 U.S. Page DISTRICT 1 of 7 coun: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF VERMONT

- - x OF INTENT TO S~K THE DEATH PENALTY. The United States of America, pursuant to the requirements of Title 18, United States Code, Section 3593(a),

FOR THE CENTRAL DISTRICT OF CALIFORNIA

" findings in regard to the following offenses against Tanji Jackson:

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA. Newport News Division

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAlVIA * * AMENDED NOTICE OF INTENT TO SEEK THE DEATH PENALTY

MIAMI DIVISION. Case No Cr-Gold (s)(s)lbandstra NOTICE OF INTENT TO SEEK DEATH PENALTY AS TO DEFENDANT IAN ORVILLE AIKEN

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION. the United States of America, by and through the

Case 1:11-cr LO Document 41 Filed 02/29/12 Page 1 of 10 PageID# 126 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

MIDDLE DISTRICT OF TENNESSEE NABHVILLE DIVISION. COMES NOW the United states of America, pursuant to 18

Case 4:04-cr WRW Document 416 Filed 10/31/2007 Page 1 of 11 U S. DIS i iilc I C(;CII?.I EAST LtiN I11S I t<i(; I i\l<k!

Fr:8 I "TAFJ. Case 2:02-cr DT Document 1541 Filed 02/13/2007 Page 1 of Defendants. UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION. ) No. 4:97CR1~1 ERW (rcm) ) ) ) ) )

ti:66 alrt I I IN THE UNITED STATES DISTRICT C URT FOR THE NORTHERN DISTRICT LUBBOCK DIVISION NOTICE OF INTENT TO SEEK THE DEATH PENALTY

AND NOW come~_th~_:united States of America, pursuant to

cr. No ,-01,-02(TFH) -03

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA. Alexandria Division ) ) ) ) ) )

01 Dt:C I 3 PM 3: 3 I

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA. (Muir, J.) UNITED STATES' NOTICE OF INTENT TO SEEK DEATH PENALTY

The defendant has been charged with first degree murder.

IN THE UNITED STATES DISTRICT COURT FOR EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION ) ) ) ) ) ) ) )

IN THE UNITED STATES DISTRICT COURT FOR T WESTERN DISTRICT OF MISSOURI SOUTHWESTERN DIVISION

Case 5:06-cr TBR-JDM Document 202 Filed 03/23/2009 Page 1 of 29

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT. Defendant COUNT 1

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS

Case 5:09-cr JHS Document 31 Filed 07/23/10 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Section 9 Causation 291

IN THE UNITED STATES DISTRICT COURT FOR T~H~E~ EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION

IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT IN AND FOR THE COUNTY OF DAVIS, STATE OF UTAH

THE ABC S OF CO AND ACCA FEDERAL PUBLIC DEFENDER CJA PANEL SEMINAR DECEMBER 15, 2017

Families Against Mandatory Minimums 1612 K Street, N.W., Suite 700 Washington, D.C

Federal Capital Offenses: An Abridged Overview of Substantive and Procedural Law

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Alexandria Division NOTICE OF INTENT TO SEEK A SENTENCE OF DEATH

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA. ) ) v.

ERRATA SHEET FOR ROBINSON, CRIMINAL LAW: CASE STUDIES & CONTROVERSIES, THIRD EDITION (as of March 25, 2013)

Case 1:15-cr AWI Document 55 Filed 07/26/16 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

No IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT. UNITED STATES OF AMERICA, Plaintiff-Appellee

Terry Lenamon s Collection of Florida Death Penalty Laws February 23, 2010 by Terry Penalty s Death Penalty Blog

- ~'. - . ~., .. ' zp DATI ipal'ry. United St.te. Attorney. Form No. JSA-33s-274 (Ed ) NOTICE or INTENt TO IIIK. S8 02 Cr.

IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT. No D.C. Docket No. 4:16-cr WTM-GRS-1

UNITED STATES DISTRICT COURT

FEDERAL STATUTES. 10 USC 921 Article Larceny and wrongful appropriation

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER

United States v. Nicoletti, et al. Criminal Docket No (KAM)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY

PART C IMPRISONMENT. If the applicable guideline range is in Zone B of the Sentencing Table, the minimum term may be satisfied by

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION GOVERNMENT S RESPONSE TO DEFENDANT S SENTENCING MEMORANDUM

Case 2:17-cr JAK Document 25 Filed 05/15/18 Page 1 of 19 Page ID #:80

F I L E D June 28, 2011

Miguel Angel Cabrera-Ozoria v. Atty Gen USA

UNITED STATES DISTRICT COURT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA EASTERN DIVISION

UNITED STATES DEPARTMENT OF JUSTICE EXECUTIVE OFFICE FOR IMMIGRATION REVIEW IMMIGRATION COURT YORK, PENNSYLVANIA

Let others know about the FREE legal resources available at LA Law Library. #ProBonoWeek #LALawLibrary

4B1.1 GUIDELINES MANUAL November 1, 2014

Copyright Crash Data Services, LLC All rights reserved.

G.S. 15A Page 1

Case 1:13-cr LJO-SKO Document 151 Filed 03/03/14 Page 1 of 7

Organized Crime And Racketeering

Crimes (Sentencing Procedure) Amendment Bill 2007

MARIN COUNTY SHERIFF'S OFFICE GENERAL ORDER. DATE Chapter 5- Operations GO /11/2014 PAGE 1 of 6. Immigration Status (Trust Act implementation)

United States District Court Western District of Kentucky PADUCAH DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO CR-ZLOCH/ROSENBAUM CASE NO CR-ZLOCH/ROSENBAUM

Evolution of the Definition of Aggravated Felony

(Reprinted with amendments adopted on May 6, 2003) SECOND REPRINT A.B. 15. Referred to Committee on Judiciary

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2005 SESSION LAW HOUSE BILL 822

UNITED STAT!S DISTRICT COURT ) ) ) ) )

UNITED STATES DISTRICT COURT

692 Part VI.b Excuse Defenses

Sentencing Factors that Limit Judicial Discretion and Influence Plea Bargaining

PLEA AGREEMENT THOMAS QUINN

OPINION BELOW. The opinion of the Tenth Circuit of Appeals is reported as Rashid v. Gonzales, 2006 WL (10 th Cir. 2006).

Examinable excerpts of. Bail Act as at 10 April 2018 PART 1 PRELIMINARY

CRIMMIGRATION. The Intersection of Criminal and Immigration Law. John Gihon Shorstein, Lasnetski & Gihon

*Zarnoch, Graeff, Friedman,

IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT. No Non-Argument Calendar. D.C. Docket No. 8:16-cr JDW-AEP-1.

Case: 1:10-cr SL Doc #: 898 Filed: 06/04/12 1 of 5. PageID #: 18606

ASSAULTS ON EMERGENCY WORKERS (OFFENCES) BILL EXPLANATORY NOTES

Deadly Justice. A Statistical Portrait of the Death Penalty. Appendix B. Mitigating Circumstances State-By-State.

POST-PADILLA ISSUES. Two-Part Test: Strickland

No. IN THE SUPREME COURT OF THE UNITED STATES. October Term 2013

Transcription:

Case :0-cr-00-JFW Document Filed 0//00 Page of 0 0 GEORGE S. CARDONA Acting United States Attorney THOMAS P. O BRIEN Assistant United States Attorney Chief, Criminal Division MARK A. YOUNG (State Bar No. ) PETER HERNANDEZ (State Bar No. 0) MICHAEL S. LOWE (State Bar No. ) Assistant United States Attorneys Narcotics Section 00 United States Courthouse North Spring Street Los Angeles, California 00 Telephone: () -// Facsimile: () -0 Email: mark.young@usdoj.gov peter.hernandez@usdoj.gov mike.lowe@usdoj.gov Attorneys for Plaintiff UNITED STATES OF AMERICA UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) RAUL ROBLEDO, ) ) Defendant. ) ) No. CR 0-(B)-JFW GOVERNMENT S AMENDED NOTICE OF INTENT TO SEEK THE DEATH PENALTY AGAINST DEFENDANT RAUL ROBLEDO AMENDED NOTICE OF INTENT TO SEEK THE DEATH PENALTY The United States of America, pursuant to U.S.C. (a), notifies the Court and defendant RAUL ROBLEDO ( defendant ), that the Government believes the circumstances of the offense charged in Count Four of the Second Superseding Indictment are such that, in the event of a conviction, a sentence of death is justified under Chapter (Sections through ) of Title of the United States Code, and that the Government will seek the sentence of death for the offense of

Case :0-cr-00-JFW Document Filed 0//00 Page of 0 0 violent crime (murder) in aid of racketeering, in violation of Title, United States Code, Section (a)(), which carries a possible sentence of death. The Government proposes to prove the following factors as justifying a sentence of death. A. Statutory Proportionality Factors Enumerated under U.S.C. (a)()(a)-(d) The following statutory proportionality factors apply to Count Four.. Intentionally Killing the Victim Defendant intentionally killed Martha Puebla. U.S.C. (a)()(a).. Intentionally Inflicted Serious Bodily Injury that Resulted in the Death of the Victim Defendant intentionally inflicted serious bodily injury that resulted in the death of Martha Puebla. U.S.C. (a)()(b).. Intentional Acts to Take Life or Use Lethal Force Defendant intentionally participated in an act, contemplating that the life of a person would be taken or intending that lethal force would be used in connection with a person, other than one of the participants in the offense, and Martha Puebla died as a direct result of the act. U.S.C. (a)()(c).. Intentionally and Specifically Engaged in an Act of Violence Creating a Grave Risk of Death

Case :0-cr-00-JFW Document Filed 0//00 Page of 0 0 Defendant intentionally and specifically engaged in an act of violence knowing that the act created a grave risk of death to a person, other than one of the participants in the offense, such that participation in the act constituted a reckless disregard for human life and Martha Puebla died as a direct result of the act. U.S.C. (a)()(d). B. Statutory Aggravating Factors Enumerated under U.S.C. (c) The following statutory aggravating factors apply to Count Four.. Substantial Planning and Premeditation Defendant committed the offense charged in Count Four after substantial planning and premeditation to cause the death of a person. U.S.C. (c)().. Defendant was previously convicted of two or more prior felony drug offenses Defendant has previously been convicted of two or more State offenses punishable by a term of imprisonment of more than one year, committed on different occasions, involving the distribution of a controlled substance. U.S.C. (c)(0). In, defendant was convicted of possession of marijuana for sale. In, defendant was convicted of possession of methamphetamine for sale. In 00, defendant was convicted of possession of marijuana for sale. C. Other, Non-Statutory, Aggravating Factors Identified under U.S.C. (a)()

Case :0-cr-00-JFW Document Filed 0//00 Page of The following non-statutory aggravating factors apply to Count Four. 0 0. The murder was committed in an attempt to obstruct justice Defendant participated in the murder of the victim because she had testified at a preliminary hearing for a co-conspirator in pretrial confinement and was expected to testify at the coconspirator s trial.. Victim Impact Evidence Defendant caused injury, harm, and loss to the family, friends, and classmates of Martha Puebla as evidenced by her personal characteristics as a human being and the impact of her death on her family, her friends, and her classmates. The Government further gives notice that in support of imposition of the death penalty it intends to rely upon all the evidence admitted by the Court at the guilt phase of the trial and the offenses of conviction as described in the Second Superseding Indictment as they relate to the background and character of the defendant, RAUL ROBLEDO, his moral culpability, and the nature and circumstances of the offenses charged in the Second Superseding Indictment. DATE: February, 00 Respectfully submitted, GEORGE S. CARDONA Acting United States Attorney

Case :0-cr-00-JFW Document Filed 0//00 Page of THOMAS P. O BRIEN Assistant United States Attorney Chief, Criminal Division MARK A. YOUNG Assistant United States Attorney Attorneys for Plaintiff United States of America 0 0

DEBRA WONG YANG United States Attorney 'THOl'l.tAS p. 0' BRIEN ~ssistant United States Attorney Chief, Criminal Division M~RK A. YOUNG (State Bar No. ) PETER HERNANDEZ (State Bar No. 0) DAVID P. KOWAL (State Bar No. ) Assistant United States Attorneys ~arcotics Section 00 uni~ed States Courthouse North Spring Street Los Angeles, California 00 Telephone: () -// Facsimile: () -0 Attorneys for?laintiff ONITSD STlI.TES OF A..IISIUC~ 0 UNITED STATES DISTRICT COURT FOR THE CENTRF.L JISTRICT OF CALIFORNIA UNITED STATES OF N~ERICA, No. CR 0-(A)-JFW i \ '. v. Plaintiff, GOVERNMENT'S NOTICE OF INTENT TO SEEK THE DEATH PENALTY AGAINST DEFENDANT RAUL ROBLEDO RAUL ROBL:::DO, Defendant. 0 NOTICE OF INTENT TO SEEK THE DEATH PENALTY The United States of America, pursuant to U.S.C. (a), notifies the Court and defendant RAUL ROBLEDO ("defendant"), that the Government believes the circumstances of the offense charged in Counts Six and Fifty-Four of the First Superseding Indictment are such that, in the event of a conviction, a sentence of death is justified under Chapter (Sections through ) of Title of the United States Code, and that the Government will seek the sentence of death for the offense of violent crime (murder) in aid of racketeering, in

violation of Ti'Cle, United States Code, Section (a) (), which carries a possible sentence of dea'ch. The Government proposes to prove the following factors as justifying a sentence of death. A. Statutory Proportionality Factors Enumerated under U.S.C. (a) () (Al-fD) The fol:owing statutory proportionality factors apply to Counts Six and Fifty-Four.. Intentionally Killing the Vict~ 0 Defendant intentionally killed Martha Puebla. U.S.C. (a) () (A) L.. Intentionally Inflicted Serious Bodily Injury that Resulted in the Death of the Vict~ ( Defendan'C intentionally inflicted serious bodily injury that resulted in the death of Martha Puebla. U.S.C. (a) () (B).. Intentional Acts to Take Life or Use Lethal Force Defendan'C intentionally participated in an act, contemplating 'Chat the life of a person would be taken or 0 intending that lethal force would be used in connection with a person, other than one of the participants in the offense, and Martha Puebla died as a direct result of the act. U.S.C. (a) () (C).. Intentionally and Specifically Engaged in an Act of Violence Creating a Grave Risk of Death Defendant intentionally and specifically engaged in an act of violence knowing that the act created a gra~e risk of death to a person, other tha~ one of the participants in the offense, such

that participation in the act constituted a reckless disregard for human life and Martha Puebla died as a direct result of the act. O.S.C. (a) () (0). B. Statutory Agaravatina Factors EnumeTated under O.S.C. (c) The following statutory aggravating factors apply to Counts Six and Fifty-Four.. Substantial Planning and Premeditation Defendant committed the offense charged in Counts Six and 0 Fifty-Four after substantial planning and premeditation to cause the death of a person. O.S.C. (c) (). \.. Defendant was previously convicted of two or more prior felony drug offenses Defendant has previously been convicted of two or more State offenses punishable by a term of imprisonment of more tha~ one year f comitti t ted on different occasions, involving the distribution of a controlled substance. O.S.C. (c)(0). :n, defendant was convicted of possession of marijuana for sale. In, defendant was convicted of possession of 0 methamphetamine for sale. In 00, defendant was convicted of possession of marijuana for sale. C. Other, Non-Statutorv, Aaaravating Factors Identified unde T U.S.C. (a) () The following non-statutory aggravating factors apply to Counts Six and Fifty-Four..

. The murder was committed in an attempt to obstruct justice Defendant par~icipated in the murder of ~he victim because she had testified at a preliminary hearing for a co-conspirator in pretrial confinement and was expected to testify at the co- conspirator's trial. ( \ 0. Vict~ Impact Evidence Defendant caused injury, harm, and loss to the family, friends, and classmates of Martha Puebla as evidenced by her personal characteristics as a human being and the impact of her death on her family, her friends, and her classmates. The Government further gives notice that in support of imposition of the death penalty it intends to rely upon all the evidence admitted by the Court at the guilt phase of the trial and the offenses of conviction as described in the First Superseding Indictment as they relate to the background and characte~ of the defendant, RAUL ROBLEDO, his moral culpability, and the nature and circumstances of the offenses charged in the Second Superseding Indictment. 0.. DATE: June, 00 Respectfully submitted, DEBPA WONG YANG United States Attorney Assistant Attorneys for Plaintiff United States of America

CERTIFICATE OF SERVICE 0 I, --'RE"-=G=IN..:..:A~A=UT~RE'_=_Y", declare: That I am a citizen ofthe United States and resident or employed in Los Angeles County, California; that my business address is the Office of United States Attorney, United States Courthouse, North Spring Street, Los Angeles, California 00; that I am over the age of eighteen years, and am not a party to the above-entitled action; That I am employed by the United States Attorney for the Central District of California who is a member of the Bar of the United States District Court for the Central District of California, at whose direction I served a copy of: GOVERNMENT'S NOTICE OF INTENT TO SEEK THE DEATH PENALTY AGAINST DEFENDANT R.\.UL ROBLEDO ;',. [ ] Placed in a closed envelope, for collection and interoffice deli vel)' addressed as follows: [ ] By hand delivery addressed as follows: [ ] By messenger as follows: SERVICE WAS: - [X] Placed in a sealed envelope for collection and mailing via United States Mail, addressed as follows: [ ] By facsimile as follows: [ ] By federal express as fo0v,!s: 0 SEE ATTACHED PROOF OF SERVICE LIST. This Certificate is executed on June, 00, at Los Angeles, California. I certify under penalty of perjury that the foregoing is true and correct ~il:l.