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Memorandum of Matters Discussed and Action Taken at Pretrial Conference — United States v. Johnson (W.D. Mo.)

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A Memorandum of Matters Discussed and Action Taken at Pretrial Conference, Document 44, filed 04/09/25, Case 4:25-cr-00006-BP, Criminal Action No. 25-00006-01-CR-W-BP, United States of America v. Rafael L. Johnson, Western District of Missouri. The pending charge is listed as Felon in Possession of a Firearm and Ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). It names trial counsel Jessica Jennings for the Government and Robert Kuchar for the defense, sets April 14, 2025 deadlines for witness and exhibit lists, voir dire, jury instructions and motions in limine, and gives a criminal jury trial docket commencing 4/28/2025. It is marked IT IS SO ORDERED /s/ Jill A. Morris, United States Magistrate Judge.

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“Memorandum of Matters Discussed and Action Taken at Pretrial Conference — United States v. Johnson (W.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-25-cr-00006-dkt-44-w-d-mo-8210b24336/, SHA-256 3d89a6cccf1768219774422cd57b3688162fe1e20eeaf89227c27a6ec658fce3.

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

UNITED STATES OF AMERICA

                             Plaintiff,

-vs-                                                              Criminal Action No.
                                                                  25-00006-01-CR-W-BP
RAFAEL L. JOHNSON,

                        Defendant.
_____________________________________

                   MEMORANDUM OF MATTERS DISCUSSED AND
                   ACTION TAKEN AT PRETRIAL CONFERENCE

The following matters were discussed and action taken during the pretrial conference:

PENDING CHARGE:              Felon in Possession of a Firearm and Ammunition
                             in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8)

TRIAL COUNSEL:
      Government: Jessica Jennings
           Case Agent: Rachel D. Alonzo, ATF
      Defense: Robert Kuchar and investigator Mark Wolpin

OUTSTANDING MOTIONS:
                                     Doc. 41-NOTICE of filing Government's Notice of Intent to
                                             Offer Evidence Pursuant to Rule 404(b) by USA as
                                             to Rafael L. Johnson

                                     Doc. 42- NOTICE of filing Government's Notice of Expert
                                              Witness by USA as to Rafael L. Johnson

ANTICIPATED MOTIONS: None

TRIAL WITNESSES:
     Government: 3 with stipulations; 4 without stipulations
     Defense: 2 witnesses, including Defendant who        ( ) will
                                                          ( x ) may
                                                          ( ) will not testify
TRIAL EXHIBITS:
     Government: 50 exhibits
     Defense: No additional exhibits

DEFENSES:
    ( x ) defense of general denial
    ( ) defenses of general denial and _________________________________________

        Case 4:25-cr-00006-BP         Document 44       Filed 04/09/25     Page 1 of 2
POSSIBLE DISPOSITION:
     ( x ) Definitely for trial                    ( ) Possibly for trial
     ( ) Motion to continue to be filed            ( ) Likely a plea will be worked out

TRIAL TIME: 2 - 2.5 days
      Government’s case including jury selection: 2 days
      Defense case: .5 day at most

STIPULATIONS:
     ( x ) in discussions, but stipulations unlikely at this time as to:
           ( x ) chain of custody
           ( ) chemist’s reports
           ( x ) prior felony conviction
           ( x ) interstate nexus of firearm
           ( ) other: ______________________________________________________

UNUSUAL QUESTIONS OF LAW: None

FILING DEADLINES:

       Witness and Exhibit Lists:
       Government: April 14, 2025
       Defense: April 14, 2025
       Counsel are requested to list witnesses in alphabetical order on their witness list.

       Exhibit Index, Voir Dire, Jury Instructions: April 14, 2025
       Jury instructions must comply with Local Rule 51.1

       Motions in Limine: April 14, 2025

TRIAL SETTING: Criminal jury trial docket commencing 4/28/2025
     Please note: Both the Government and Defendant request that the case be set during the
     first week of the trial docket. The Government’s case agent—who also serves as its
     expert on the nexus of the firearm—is unavailable beginning late on May 2 through May
     8, 2025. Additionally, Defendant’s investigator is unavailable during the second week
     of the trial docket.

OTHER:
    ( )       A _____________________-speaking interpreter is required.
    ( )       Other assistive devices:

       IT IS SO ORDERED.
                                                           /s/ Jill A. Morris
                                                           JILL A. MORRIS
                                                           United States Magistrate Judge

                                              2



        Case 4:25-cr-00006-BP        Document 44       Filed 04/09/25     Page 2 of 2

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