IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Criminal Action No. 11-cr-355-MSK

UNITED STATES OF AMERICA,

Plaintiff,

v.

1. WAUNITA WEINGART,

2. JOHN PHILLIP GALLEGOS,

3. ALOIS CRAIG WEINGART,

Defendants.

GOVERNMENT’S MOTION FOR LEAVE 

TO DISCLOSE REPORTS OF INTERVIEWS

The United States of America, by and through Assistant United States Attorneys 

Linda Kaufman and Martha Paluch, hereby seek leave of the Court to disclose to 

defense counsel five reports of interviews of witnesses. In support of this motion, the 

United States states as follows:

1. All five witnesses were endorsed on the Government’s Witness List 

provided to defense counsel on September 17, 2012. All five witnesses were 

interviewed by agents in this case prior to September 17, 2012, but undersigned 

counsel discovered late last week that these reports had not been disclosed.

2. By these disclosures, the government would not be augmenting the 

number or identity of its witnesses or exhibits. 

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3. Undersigned counsel conferred with Ms. Paula Ray, counsel for Craig 

Weingart, regarding this motion. Ms. Ray stated that she does not object to the 

disclosure of these reports of interviews.

4. Undersigned counsel conferred with counsel for Waunita Weingart and 

John Gallegos, regarding this motion. Through counsel, Mr. Gallegos and Ms. 

Weingart take the position that the memoranda should be disclosed immediately, but 

do not waive and hereby reserve the right to object to the admission of the testimony of 

the witnesses whose interviews are summarized therein and/or to seek other sanctions 

for the government’s violation of the Court’s order requiring the government to 

complete its disclosures to the defense in this case not later than September 17, 2012.

5. The United States submits that the disclosure of these five reports of 

interviews at this time will not prejudice the defense.

6. For these reasons, the United States respectfully requests leave of the 

Court to disclose these five reports of interviews to defense counsel.

Respectfully submitted this 29th day of October, 2012.

JOHN F. WALSH

United States Attorney

By: s/ Linda Kaufman 

LINDA KAUFMAN

By: s/ Martha Paluch

MARTHA PAULCH

Assistant United States Attorneys

1225 Seventeenth Street, Suite 700

Denver, Colorado 80202

Telephone: (303) 454-0100

Facsimile: (303) 454-0404

E-mail: Linda.Kaufman@usdoj.gov

 Martha.Paluch@usdoj.gov

Case No. 1:11-cr-00355-MSK Document 166 filed 10/29/12 USDC Colorado pg 2 of 3
CERTIFICATE OF SERVICE

I certify that on this 29th day of October, 2012, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF system which will send notification of such 

filing to the following e-mail addresses:

Martin Adam Stuart

E-mail: martinstuartlaw@solucian.com

Darlene Ann Bagley

E-mail: bagley@ridleylaw.com

William Lewis Taylor

E-mail: wltaylorpc@gmail.com

Paula M. Ray

E-mail: paulamray@earthlnk.net

 

By: s/ Deborah Sisung 

DEBORAH SISUNG

Legal Assistant to AUSA Linda Kaufman

United States Attorney’s Office

1225 - 17th Street, Suite 700

Denver, CO 80202

Telephone: (303) 454-0244

Fax: (303) 454-0402

E-mail: deborah.sisung@usdoj.gov

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