’” Roberts v. Galen of Va., Inc., 325 F.3d 776, 784 (6th Cir. 2003) (quoting Fed. R. Evid. 615). The corporate defendant Accredo, however, should not be permitted to skirt Fed. R. Evid. 615 by designating representatives who are identified witnesses to sit in the courtroom. Accordingly, Lead Plaintiffs request that the Court prohibit Accredo from naming as its representative any person who has been identified as a potential witness in this case.

Thus, Rogan requests that the Court sequesters all actual and potential witnesses with the exception of the designated representative for each party. CONCLUSION WHEREFORE, Defendant Peter Rogan respectfully requests that this Court enter an order in conformity with Federal Rule of Evidence 615 excluding all witnesses excepted the parties' designated representatives from the courtroom during the trial of this matter and proceedings related to trial. Case: 1:02-cv-03310 Document #: 161 Filed: 03/15/06 Page 2 of 4 PageID #:1772 3 Dated: March 15, 2006 Respectfully submitted, PETER ROGAN By: ________s/Bryna J. Dahlin________________ One of His Attorneys Neil E. Holmen Joseph A. Spiegler Bryna J. Dahlin Chris J. Stathopoulos WINSTON & STRAWN 35 West Wacker Drive Chicago, Illinois 60601 (312) 558-5600 Case: 1:02-cv-03310 Document #: 161 Filed: 03/15/06 Page 3 of 4 PageID #:1773 CERTIFICATE OF SERVICE I certify that the foregoing Defendant's Motion to Exclude Nonexpert Witnesses from the Courtroom During Trial has been served upon the following counsel this 15th day of March, 2006 as indicated below: Laurie Oberembt (by federal express) Trial Attorney Ben Franklin Station P.O. Box 261 Washington, D.C. 2

Mr. Eskridge will assist in identifying technical discrepancies in Mr. Zada’s and Ms. Poblete’s testimony regarding the backdating of the documents. For these reasons, Rule 615(c) exempts Plaintiffs’ expert witnesses from exclusion. Plaintiffs respectfully request that the Court permit Mr. Boyles and Mr. Eskridge to remain in the courtroom during trial.

Because nothing has changed, it should do the same with the instant motion. Case 2:01-cv-03894-RB Document 745 Filed 10/30/15 Page 5 of 8 6 III. CONCLUSION Federal Rule of Evidence 615(a) establishes the right of Plaintiffs to attend all of the trial, not just the portion after they testify. The Third Circuit protects that right.

This rule, however, deals with sequestration so that a witness cannot hear the testimony of another witness, and has nothing to do with whether he should be barred from access to confidential information. A. Fed. R. Evid. 615 Does Not Require Ceste To Be Barred From All Confidential Information. Rational states that Ceste’s memory could be influenced if he reviews Rational confidential information concerning meetings with Rational at which he was present, and about which he will be called to testify.

The fourth permits a district court to allow a witness to remain when “a party shows” his presence “to be essential to presenting the party’s claim or defense.” Fed. R. Evid. 615(c). Singh has not met his burden to show that Simerneet is “essential” to his defense within the meaning of Rule 615.

Rule 615 contains certain specific exceptions to the general rule of exclusion of witnesses, including parties to the action, officers or employees of a party, and persons whose presence a party shows to be essential to presenting the party's claim or defense. See FRE 615 (a)-(c). In this instant action, there will be a number of lay and expert witnesses who will be called to testify at trial regarding certain factual issues in this case.

Defendant True’s motion is based on Federal Rule of Evidence 615(3), which provides an exception to the rule on witnesses for “a person whose presence is shown by a party to be essential to the presentation of the party’s cause.” Fed. R. Evid. 615(3). The Court should deny defendant True such an exception for his testifying wife.

Without the assistance of Mrs. True, defense counsel will be unable to effectively manage the massive amounts of evidence in this case. B. Sequestration of Mrs. True does not further the purpose of FRE 615 The purpose of Rule 615 is twofold: “It exercises a restraint on witnesses ‘tailoring’ their testimony to that of earlier witnesses; and it aids in detecting testimony that is less than candid.” Geders v. United States, 425 U.S. 80, 87 (1976).

Mr. Wedding requests that all witnesses be excluded from the courtroom until they are excused from service, pursuant to FRE 615. Should the law enforcement agent chosen by the government to sit at counsel’s table during trial be a percipient witness, Mr. Wedding would ask that the case agent’s testimony be taken first, so as not to violate the spirit of FRE 615. Case 3:08-cr-02386-JM Document 112 Filed 07/10/09 Page 19 of 20 MOTIONS IN LIMINE US v RYAN WEDDING 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 THIS COURT SHOULD GRANT LEAVE TO FILE OTHER MOTIONS To the extent that there is outstanding discovery that the government has not yet produced or the interest of fairness or judicial economy otherwise require it, Mr. Wedding requests leave to file further motions in limine or orally make such motions as may be necessary.