Court filing

Motion for Notice of Intent to Introduce Other Acts Evidence — USA v. Harun (Dkt. 79, S.D. Ga.)

Summary

A Motion for Notice of Evidence of Other Crimes, Wrongs or Acts to Be Used Against the Defendant in United States of America v. Gladys Harun, Case No. 3:22-CR-09, in the U.S. District Court for the Southern District of Georgia, Dublin Division, filed January 24, 2023 as Doc. 79. The defendant, Gladys Harun, a/k/a "Gladys Chege," moves under Fed. R. Evid. 404(b) and L. Cr. R. 16.2 for an order requiring the United States of America to give reasonable notice, in advance of trial, of the general nature of any evidence of other crimes, wrongs or acts it intends to introduce, and its purpose for the evidence. The motion is signed /s/ D. Robert Busbee, with a certificate of service referring to the notice of electronic filing.

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Filed January 24, 2023 in USA v. Harun; one of 109 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of Georgia
Filed	2023-01-24

Cite this document

“Motion for Notice of Intent to Introduce Other Acts Evidence — USA v. Harun (Dkt. 79, S.D. Ga.).” U.S. District Court for the Southern District of Georgia, No. 3:22-cr-00009-DHB-BKE, Doc. 79, filed 2023-01-24. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-gladys-harun-gasd-87462/2023-01-24-gov-uscourts-gasd-87462-79-0-doc-79/, SHA-256 87b4aeb423bd5e8c1f4c71cc82870847ebe6af5512d064de2844f5d75c4f9758.

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Full text

Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
DUBLIN DIVISION
UNITED STATES OF AMERICA
)
)
v.
)
CASE NO. 3:22-CR-09
)
GLADYS HARUN, a/k/a “GLADYS
)
CHEGE”
)

)
MOTION FOR NOTICE OF EVIDENCE OF OTHER CRIMES, WRONGS OR ACTS
TO BE USED AGAINST THE DEFENDANT
COMES NOW the Defendant, Gladys Harun, a/k/a “Gladys Chege”, (hereinafter, the
“Defendant”), by and through counsel, pursuant to Fed. R. Evid. 404(b) and L. Cr. R. 16.2, and
hereby respectfully moves this Honorable Court to order the United States of America (hereinafter
“Government”) to provide reasonable notice to Defendant of the general nature of any and all
evidence of other crimes, wrongs or acts, which the Government intends to introduce against
Defendant, in advance of trial, and the Government’s purpose for its intended use of such evidence.
See Fed. R. Evid. 404(b)
RESPECTFULLY SUBMITTED this 24th day of January, 2023.
By: /s/ D. Robert Busbee

D. Robert Busbee, Esq.
Georgia Bar No. 186336
Attorney for Defendant Gladys Harun, a/k/a “Gladys
Chege”

Busbee Law Group, LLC
8 East Grady Street
Statesboro, Georgia 30458
(912) 225-1311 - Office
(866) 320-7606 - Fax
drb@busbeelawgroup.com

Case 3:22-cr-00009-DHB-BKE Document 79 Filed 01/24/23 Page 1 of 2

Page 2 of 2
CERTIFICATE OF SERVICE
This is to certify that I have on this day served all the parties in this case in accordance with
the notice of electronic filing (“NEF”) which was generated as a result of electronic filing in this
Court.
RESPECTFULLY SUBMITTED this 24th day of January, 2023.
By: /s/ D. Robert Busbee