PEOPLE v. WILLIAMS (GEORGE)Appellant’s Focus Issues LetterCal.August 12, 2016PAUL J. SPIEGELMAN weAN , ATTORNEY AT LAw & > P.O”. Box 22575 & SAN DIEGO, CA 92192-2575 RECEIVED mseSUPREME COURT COPYAUG 1 9 2016 August 9, 2016 CLERKSUPREME COURT & SUPREME COURT Supreme Court ofCalifornia : Y Office ofthe Clerk, Death Penalty Appeals 612 2016 350 McAllister Street, Room 1295 FrankA. McGuire Clerk San Francisco, CA 94102-4797 a | Deputy Re: People v. Williams, §131819 Oral Argument Gentlepersons: Please be advised that as counsel for appellant in the above matter, I hereby request 45 minutes for argumentofthis death penalty case. I intend to focus on three issues (numbered as they were in appellant’s briefs): Issue I: Was it prejudicial error in the guilt phase to refuse to grant a mistrial when a key government witness changedhis testimony after the defense had promised the jury in its opening statementthat this witness would testify favorably to the defense and when the defense would not have openedits case relying onthis testimony but for a discovery violation by the prosecution which wasonly revealed after the defense opening statement? Issue IV: Was Appellant denied a fair guilt phase trial when the trial judge allowed the prosecution to introduce prior sex offenses under Evidence Code section 1108 and use them notfor the purpose ofproving whether the sex act in this case was consensual, but rather for the purpose ofprejudicing the jury against defendant on the murder charge? Issue VI: Did the trial judge commit prejudicial error in the penalty phase whenherefused the defense request to instruct the jury not to allow racial bias to influence their decision in a case in which a black man had been convicted of DEATPENALTY raping and killing a white girl who was fourteen years old and there was substantial evidence (A)in the guilt trial that the victim had hidden her relationship with a black man for fear of backlash from her family and (B)in the penalty trial concerning appellant’s upbringing in a racially segregated and economically deprived circumstances? Enclosedis an original Supreme Court Appearance Sheet and a declaration of service showing service by mail on the Attorney Generalas well as appellant and the California Appellate Project. Thank you for yourattention to these matters. Respectfully yours, Paul J. Spiegelman Attorney for Appellant George Williams,Jr. Cc: Kamala Harris, Attorney General Aundre Herron, StaffAttorney, California Appellate Project George Williams, Jr., Appellant DECLARATION OF SERVICE BY MAIL Re: People v. Williams Supreme Court No. I, Paul J. Spiegelman, declare that I am over 18 years of age and am not a party in this action. My business address is P.O. Box 22575, San Diego, CA 92192-2575. I served a copy ofthe attached Letter of August 9, 2016 on each ofthe following by placing same in an envelope addressed respectively as follows: Kamala Harris, Attorney General 110 West A Street, Suite 1100 San Diego, California 92101 Aundre Herron, StaffAttorney Calfiornia Appellate Project 101 Second Street San Francisco, CA 92105 Mr. George Williams, Jr. V-70703 SQSP 5EB70 San Quentin, CA 94974 Each said envelope was than on August 9, 2016, sealed and deposited in the United States Mail at San Diego, California with postage fully prepaid I declare under penalty ofperjury that the foregoing is true and correct. Executed at San Diego, California, this 9 day ofA2016. Fat ~Me ee PAUL J. “ahobewan Declarant
