state v. lowell barron motion for order requiring state filings under seal
TRANSCRIPT
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7/30/2019 State v. Lowell Barron Motion for Order Requiring State Filings Under Seal
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IN THE CIRCUIT COURT FOR
DeKALB COUNTY, ALABAMA
STATE OF ALABAMA, )
)
Plaintiff, ))
vs. ) CASE NO. CC-2013-77
)LOWELL RAY BARRON, )
)
Defendant. )
DEFENDANT LOWELL RAY BARRONS MOTION FOR ORDER
REQUIRING STATE FILINGS UNDER SEAL
Defendant Lowell Ray Barron respectfully moves for an order that the State must
not file any document that contains or includes any allegation about Defendants or any
evidence pertaining to Defendants in any way, unless such filing is under seal.
This motion pertains, for instance, to any response the State may file, to Barrons
request for notice of any evidence the State might seek to admit under Ala. R. Evid.
404(b). This motion pertains also to Barrons discovery requests. This motion pertains,
even beyond that, to any document that the State may file in this Court that includes any
allegation about Defendants (with the exception of any document that does nothing more,
in this respect, than quoting the indictment), or any filing by the State that contains any
statement of expected testimony, or any filing by the State that otherwise discusses any
evidence pertaining to Defendants.
Granting this motion would not cause any cognizable harm to the State in any
respect. Granting this motion would not stop the State from filing any document, but
would only ensure that such filings are under seal so that they do not undermine the
ELECTRONICALLY FILED5/8/2013 3:22 PM
28-CC-2013-000077.00CIRCUIT COURT OF
DeKALB COUNTY, ALABAMAPAM SIMPSON, CLERK
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7/30/2019 State v. Lowell Barron Motion for Order Requiring State Filings Under Seal
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likelihood of a fair trial. If any party then seeks to unseal any sealed filing, the Court
would of course be able to consider any such request.
Respectfully submitted,
__s/ Joe Espy, III______________Joe Espy, III (ESP002)
One of the Attorneys for Defendant
Lowell Ray Barron
OF COUNSEL:
Benjamin J. Espy (ESP005)
William M. Espy (ESP007)MELTON, ESPY & WILLIAMS, P.C.
P.O. Drawer 5130
Montgomery, AL 36103Telephone: 334-263-6621
Facsimile: 334-263-7252
[email protected]@mewlegal.com
Winfred Rocky WatsonWatson & Neeley, LLC
305 Grand Avenue, SW
Fort Payne, AL 35967
Telephone: [email protected]
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served electronically via AlaFile on this
the 8th day of May, 2013.
Matt Hart, Deputy Attorney General
Bill Lisenby, Deputy Attorney GeneralPeter Smyczek, Deputy Attorney General
State of Alabama Office of the Attorney GeneralPO Box 300152Montgomery, AL 36130-0152
s/ Joe Espy, III
Of Counsel
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