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PETITION FOR WRIT OF MANDAMUS OF PETITIONER-DEFENDANT, TIMOTHY JAMES McVEIGH AND BRIEF IN SUPPORT MARCH 25, 1997 |
XI. SPECIFIC RELIEF REQUESTED Petitioner requests that a Writ of Mandamus issue to the Respondent Judge of the District Court directing him to command the government to produce the material requested in the manner outlined by the defense in sealed district court documents D.E. 1079, 2265, 2533, 2768, and 3123. Additionally, Petitioner requests that the writ include a direction to the district court compelling the government to produce information responsive to 2 of Exhibit "A" attached to this Petition which is a document with the heading "Department of Statement Diplomatic Security." This paragraph indicates that certain military record checks were pending and that results would be forwarded to the government by separate telegram. The defense requests the documents provided to the government in the separate telegram. Petitioner also requests that this Court, while considering these matters, either stay the commencement of the trial or in the alternative, allow the district court to proceed with jury selection but stay the commencement of evidence being received until these issues have been resolved in this Court. Respectfully submitted, L Stephen Jones, OBA #4805 Robert Nigh, Jr., OBA #011686 of JONES, WYATT & ROBERTS Denver Place South Tower 999 18th Street, Suite 2460 Post Office Box 8257 Denver, Colorado 80201 Phone: 303/299-9050 FAX: 303/299-0045 Richard Burr, FBA #407402 Denver Place South Tower 999 18th Street, Suite 2460 Post Office Box 8257 Denver, Colorado 80201 Phone: 303/299-9050 FAX: 303/299-0045 Jeralyn E. Merritt, Esquire 303 East 17th Avenue, Suite 400 Denver, Colorado 80203 Phone: 303/837-1837 FAX: 303/832-7822 Cheryl A. Ramsey, OBA #7403 Szlichta & Ramsey Post Office Box 1206 Stillwater, Oklahoma 74076 Phone: 405/377-3393 Christopher L. Tritico, TBA #20232050 Essmyer, Tritico & Clary, LLP 4300 Scotland Houston, Texas 77007 Phone: 713/869-1155 Of Counsel Robert L Wyatt, IV, OBA #13154 Michael D. Roberts, OBA #13764 James L. Hankins, OBA #15506 Randall T. Coyne, MBA #549013 Amber McLaughlin, TBA #13740980 Robert J. Warren, OBA #16123 Mandy Welch, TBA #21125380 Holly Hillerman, OBA #017055 ATTORNEYS FOR DEFENDANT TIMOTHY JAMES McVEIGH CERTIFICATE OF HAND DELIVERY This is to certify that on the 25 day of March, 1997, a true and correct copy of the above and foregoing PETITION FOR WRIT OF MANDAMUS OF PETITIONER-DEFENDANT, TIMOTHY JAMES McVEIGH, AND BRIEF IN SUPPORT was hand delivered to: Joseph H. Hartzler, Esquire Sean Connelly, Esquire Special Attorneys to the U.S. Attorney General U.S. Department of Justice 1961 Stout Street, Suite 1200 Denver, Colorado 80294 Michael Tigar, Esquire Ronald G. Woods, Esquire N. Reid Neureiter, Esquire Adam Thurschwell, Esquire 1120 Lincoln, Suite 1308 Denver, Colorado 80203 The Honorable Richard P. Matsch c/o Jim Manspeaker, Federal District Court Clerk 140 U.S. Courthouse 1929 Stout Street Denver, Colorado 80294
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PETITION FOR WRIT OF MANDAMUS OF PETITIONER-DEFENDANT, TIMOTHY JAMES McVEIGH AND BRIEF IN SUPPORT MARCH 25, 1997 |