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UNITED STATES DISTRICT COURT
for the Western District of Michigan

Criminal Division--Felony Branch

UNITED STATES OF AMERICA

 

     
 
 
 
v.
   
# 03-203-02

ANGELA SMITH, et al

 

     
 
 
 
 

NOTICE OF INTENTION TO OFFER A DEFENSE OF ALIBI

Pursuant to Fed. R. Crim. P. 12.1, Notice of Alibi, defendant hereby responds to the government’s alibi demand by filing this Notice of Intention to Offer a Defense of Alibi.

1. On September 21, 2003, the government served upon defendant Michael Jones a written alibi demand stating the time, date, and place at which the alleged offense was committed. Defendant’s response, filed this 30th day of September 2003, is therefore timely.


2. Defendant intends to present an alibi defense. Defendant declares that at the date and time of the alleged offense, defendant Jones was with his friend Ms. Susan Brown at Ms. Brown’s apartment, located at 3442 Southerly Place, Apt. 3-C, East Murdoch Village. Defendant intends to call Ms. Brown as a witness at trial to establish his defense of alibi.

3. Defendant, having satisfied the government’s Fed. R. Crim. P. Rule 12.1(a) demand, hereby demands in turn that the attorney for the government serve upon defendant’s attorney, Ms. Susan Chase, Esq., a written notice stating the names and addresses of the