Opinion
NO. 3:10-00260-02
03-30-2012
UNITED STATES OF AMERICA v. ABDULLAHI SADE AFYARE
JAMES A. SIMMONS, #10107 Attorney for Abdullahi Sade Afyare Hendersonville, TN 37077
JUDGE HAYNES
DEFENDANT ABDULLAHI SADE AFYARE'S MOTION FOR
INTRODUCTION OF F.R.E. 412 EVIDENCE
Comes now the Defendant, Abdullahi Sade Afyare, by and through the undersigned counsel, James A. Simmons, and pursuant to F.R.E.412, moves to introduce evidence regarding "other sexual behavior" of JD2 at trial. In support of this motion, the Defendant joins and incorporates the memorandum of law in opposition to the Government's motion in limine and in support of this motion for introduction of F.R.E. 412 filed by Defendant Andrew Kayachith.
WHEREFORE, Defendant Abdullahi Sade Afyare requests that this Honorable Court conduct an in camera hearing giving the victim and the parties a right to attend and be heard, and at the conclusion of said hearing, deny the Government's Motion in Limine and grant the Defendant's Motion for introduction of "other sexual behavior" pertaining to JD2.
Respectfully submitted,
_________________
JAMES A. SIMMONS, #10107
Attorney for Abdullahi Sade Afyare
Hendersonville, TN 37077