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  • Defendant's Joint Motion For Mistrial

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    William Baroni and Bridget Kelly filed a joint motion for a mistrial in their criminal case based on several instances of alleged prosecutorial misconduct. Their attorneys argued that the prosecution made inappropriate statements during opening arguments and introduced irrelevant evidence intended to inflame the jury against the defendants. They believe these actions prejudiced the jury and denied the defendants a fair trial. If the motion is denied, they request alternative relief such as striking certain testimony and giving a strong curative instruction to the jury.

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    Motion from Bridgegate defendants Baroni and Kelly for a mistrial.

    Original Title

    Defendant's Joint Motion for Mistrial

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    William Baroni and Bridget Kelly filed a joint motion for a mistrial in their criminal case based on several instances of alleged prosecutorial misconduct. Their attorneys argued that the prosecution made inappropriate statements during opening arguments and introduced irrelevant evidence intended to inflame the jury against the defendants. They believe these actions prejudiced the jury and denied the defendants a fair trial. If the motion is denied, they request alternative relief such as striking certain testimony and giving a strong curative instruction to the jury.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    17K views5 pages

    Defendant's Joint Motion For Mistrial

    Uploaded by

    NBCNewYork
    William Baroni and Bridget Kelly filed a joint motion for a mistrial in their criminal case based on several instances of alleged prosecutorial misconduct. Their attorneys argued that the prosecution made inappropriate statements during opening arguments and introduced irrelevant evidence intended to inflame the jury against the defendants. They believe these actions prejudiced the jury and denied the defendants a fair trial. If the motion is denied, they request alternative relief such as striking certain testimony and giving a strong curative instruction to the jury.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 5

    Case 2:15-cr-00193-SDW Document 268 Filed 11/03/16 Page 1 of 1 PageID: 8663

    UNITED STATES DISTRICT COURT


    DISTRICT OF NEW JERSEY
    UNITED STATES OF AMERICA
    Case No.: 15-cr-193 (SDW)
    v.
    WILLIAM E. BARONI, JR. and
    BRIDGET ANNE KELLY

    TO:

    DEFENDANTS JOINT
    NOTICE OF MOTION
    FOR A MISTRIAL PURSUANT TO
    FEDERAL RULE OF CRIMINAL
    PROCEDURE 26.3

    Lee M. Cortes, Jr., Asst U.S. Attorney


    United States Attorneys Office
    970 Broad Street
    Newark, NJ 07102
    PLEASE TAKE NOTICE that William E. Baroni, Jr., (Michael A. Baldassare, Esq.,

    appearing) and Bridget Anne Kelly (Michael Critchley, Esq., appearing) hereby move for a
    mistrial pursuant to Federal Rule of Criminal Procedure 26.3.
    PLEASE TAKE FURTHER NOTICE that in support of this motion, Mr. Baroni and
    Ms. Kelly rely upon the brief filed herewith, a reply brief, and oral argument.
    By: /s/ Michael Baldassare
    Michael Baldassare, Esq.
    BALDASSARE & MARA, LLC
    570 Broad Street
    Newark, New Jersey 07102
    Telephone: 973-200-4066
    Attorneys for William E. Baroni, Jr.
    Date: November 3, 2016

    Case 2:15-cr-00193-SDW Document 268-1 Filed 11/03/16 Page 1 of 4 PageID: 8664

    VIA ECF
    November 3, 2016
    The Honorable Susan D. Wigenton,
    United States District Judge
    District of New Jersey
    Martin Luther King Building & U.S. Courthouse
    50 Walnut Street
    Newark, New Jersey 07101

    Re:

    United States v. William E. Baroni, Jr. and Bridget Anne Kelly,


    Criminal No.: 15-00193 (SDW)

    Dear Judge Wigenton:


    On behalf of defendants William E. Baroni, Jr. and Bridget Anne Kelly (Defendants),
    we respectfully submit this letter brief in support of a motion for a mistrial pursuant to Fed. R.
    Crim. P. 26.3.

    Case 2:15-cr-00193-SDW Document 268-1 Filed 11/03/16 Page 2 of 4 PageID: 8665

    Case 2:15-cr-00193-SDW Document 268-1 Filed 11/03/16 Page 3 of 4 PageID: 8666

    Case 2:15-cr-00193-SDW Document 268-1 Filed 11/03/16 Page 4 of 4 PageID: 8667

    Respectfully,

    Michael Baldassare

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