PEOPLE v. ADAMSAppellant’s Focus Issues LetterCal.August 18, 2014 SUPREME COURT COPY RONALD F. TURNER @[rState Bar # 109452 ~321 High School Rd. NE Suite D3 PMB 124 Bainbridge Island, WA 98110 SUPREME COURTTelephone: (916) 396-6412 FILED Office ofthe Clerk .F Nan ufSupreme Court of California rank A. McGuire Clerk 350 McAllister Street Deputy San Francisco, CA 94102 Attention: Mary Jameson, Deputy Clerk Re: People v. Marcus Adams, Crim. No. $118045 Oral Argument Focus Issues Dear Ms. Jameson: The above-entitled case is scheduled for Oral Argument on September 3, 2014. Asappellate counsel, I expect to focus on the following two issues presented in Appellantis Opening Brief duringoral argument: I. APPELLANT’S CONVICTIONS FOR MURDER MUSTBE REVERSED BECAUSE THE PROSECUTION ELICITED “WITNESS INTIMIDATION” EVIDENCE AND ALLEGED THAT APPELLANT INTIMIDATED WITNESSES WITHOUT PRESENTING SUFFICIENT EVIDENCE THAT APPELLANT PERSONALLY ACTED TO INSTILL FEAR IN ANY WITNESS, OR DIRECTED OR AUTHORIZED OTHERS TO ATTEMPT TO INTIMIDATE ANY WITNESS. I. THE . PROSECUTOR COMMITTED MISCONDUCT IN THE PENALTY PHASE BY ARGUING THAT APPELLANT’S MITIGATING EVIDENCE OF CHILDHOOD ABUSE BY HIS GRANDMOTHER WAS UNRELIABLE BECAUSE HIS SISTERS DID NOT TESTIFY TO THIS, WHERE THE PROSECUTOR KNEW THEY HAD CONFIRMED THIS ABUSE IN THE STARKEST TERMS. [unMPLtr RONALDF. TURNER D)EATH PEINALYY Attorney * Law RECEIVE D AUG 1 8 2014 OLERKSUPREME COURT _ DECLARATION OF SERVICE BY MAIL Case Name: People v. Marcus Adams Case No.: S$118045 I, Ronald Turner, declare that I am a citizen of the United States, over the age of 18 years and not a party to the within action; my business address is 321 High School Rd. NE Suite D3 PMB 124, Bainbridge Island, WA 98110. On August 15, 2014, I served the attached Oral ArgumentFocusIssues Letter by placing a true copy thereof in an envelope addressed to the person named below at the address shown, and by sealing and depositing said envelope in the United States Mail at Elk Grove, California, with postage thereon fully prepaid. Thereis delivery service by United States Mail at the place so addressed, for there is regular communication by mail between the place of mailing and the place so addressed. Colleen Tiedeman, D.A.G. Office of the Attorney General 300 South Spring St., Suite 1702 Los Angeles, CA 90013 I declare under penalty of perjury under the laws of the State of California that the foregoing is true andcorrect. Executed on August 15, 2014, at Bainbridge Island, Washington... fondnn Declarant
