UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

United States of America
    Prosecutor
     Case # 10 CR 1154 (KMW)
      v.


Julian Heicklen
   Defendant

NOTICE OF MOTIONS


    Defendant’s motion for a jury trial is enclosed.

    Defendant’s motion for witnesses is enclosed.

    Defendant’s motion for pre-trial interviews is enclosed.

    Defendant’s motion for response dates is enclosed.

_________________
Julian Heicklen
Defendant
Counsel Pro Se
734 Rutland Avenue
Teaneck, NJ 07666
814–880–9308
jph13@psu.edu


______________
Date


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

United States of America
    Prosecutor
     Case # 10 CR 1154 (KMW)
      v.

Julian Heicklen
   Defendant

    MOTION FOR A JURY TRIAL

    Defendant moves for a jury trial by an impartial jury as guaranteed by Amendment VI of the U. S. Constitution in all criminal trials.  In selecting an impartial jury Statute 18 U.S.C. § 243 Exclusion of jurors on account of race or color states:

“No citizen possessing all other qualifications which are or may be prescribed by law shall be disqualified for service as grand or petit juror in any court of the United States, or of any State on account of race, color, or previous condition of servitude;”

This statute does not exempt disqualification based on political or religious beliefs.  It does exempt disqualification based on previous time served in a jail, prison, or correctional institution.

MOTION FOR WITNESSES

    Defendant moves for witnesses on his behalf as guaranteed by Amendment VI of the U. S. Constitution in all criminal trials.  These include, but are not limited to, the following:

The juror alleged in the indictment to have been tampered.
All the jurors alleged in the indictment who were on the jury that Defendant was alleged to have tampered.
All undercover agents who discussed jury nullification with Defendant.  These include, but are not limited to, the two agents whose recordings have been sent to Defendant.
All members of the grand jury which indicted Defendant.
All other witnesses who may be called to testify by the prosecution.
Expert witnesses

   MOTION FOR PRE-TRIAL INTERVIEWS

    For the purpose of obtaining depositions, Defendant moves for separate interviews with each of the above mentioned witnesses in the presence of a court reporter and a person who can and will administer an oath (Local Civil Rule 30.3).  The U. S. Attorney shall be ordered to provide the names, identifying information, and contact information for all these individuals (Local Civil Rule 26.4).


MOTION FOR RESPONSE DATES

    In conformance with Local Civil Rule 6.1. (2) Defendant moves for a response date of January 3, 2012 from the United States of America, a hearing on the motions at the conference of January 9, 2012, and written decisions by the Court by January 16, 2012.



_________________
Julian Heicklen
Defendant
Counsel Pro Se
734 Rutland Avenue
Teaneck, NJ 07666
814–880–9308
jph13@psu.edu


______________
Date

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

United States of America
    Prosecutor
     Case # 10 CR 1154 (KMW)
      v.


Julian Heicklen
   Defendant

AFFIDAVIT AND CERTIFICATE OF SERVICE

    Defendant certifies under penalty of perjury, that DEFENDANT’S NOTICE OF MOTIONS and MOTIONS are not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation.  The sole purpose is to obtain information in the absence of other witnesses before trial, so that Defendant can prepare a defense.

Defendant further certifies that DEFENDANT’S NOTICE OF MOTIONS and MOTIONS were sent by certified U. S. mail on December 19, 2011, to the following:

CC: Pro Se Clerk, U. S. District Court, Southern District of New York, 500 Pearl Street, New York, New York, 10007

Judge Kimba Wood, U. S. District Court, Southern District of New York, U. S. Courthouse, 500 Pearl Street, New York, NY 10007

Assistant U. S. Attorney, Rebecca Mermelstein, S. D. N. Y., U. S. Courthouse, 300 Quarropas Street, White Plains, NY 10601

S. Federal Public Defender Sabrina Shroff, Federal Defenders of New York, Inc., Southern District, 52 Duane Street–10th Floor, New York, NY 10007

Attorney Adam Sudbury, 404 E. Central Boulevard, # 307, Orlando, FL 32801–1923

Mark Schmidter, 3609 Shader Road, Orlando, FL 32808

John Wolfgram, 8000 Michigan Bluff Road, Foresthill, CA 95631



______________________
Julian Heicklen
Defendant
Counsel Pro Se
734 Rutland Avenue
Teaneck, NJ 07666
814–880–9308
jph13@psu.edu


_____________________
Date