USA v. Cruz-Hernandez

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JAIME CRUZ-HERNANDEZ,
Defendant.
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Case No. 26-00037-01-CR-W-DGK
MEMORANDUM OF MATTERS DISCUSSED AND
ACTION TAKEN AT PRETRIAL CONFERENCE
PENDING CHARGE: On January 28, 2026, the Grand Jury returned a one-count Indictment
charging Defendant Cruz-Hernandez with illegal re-entry by a deported alien in violation of Title
8, United States Code, Sections 1326(a).
The following matters were discussed and action taken during the pretrial conference:
TRIAL COUNSEL:
Government: Rudolph Robert Rhodes, IV
Case Agent: Special Agent Douglas Bemiss, Department of Homeland Security
Investigations
Paralegal: Bonnie Kaiser
Defense: Angela Williams
Investigator: Kendra Jackson
CERTIFICATE OF COMPLIANCE: The Government and defense counsel have certified that
each have produced all discovery in accordance with the deadlines established in the Arraignment
and Discovery Order and have timely complied with all pretrial filing deadlines established by the
Scheduling and Trial Order up to the date of the pretrial conference.
OUTSTANDING MOTIONS: No outstanding motions.
TRIAL WITNESSES:
Government: 5 with stipulations; 7 without stipulations
Defendant: 1 witness, including the Defendant
TRIAL EXHIBITS:
Government: approximately 13 with stipulations; 15 exhibits without stipulations
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Defendant: approximately no more than 10 exhibits
DEFENSES: General denial.
POSSIBLE DISPOSITION:
(X) Definitely for trial; ( ) Possibly for trial; ( ) Likely a plea will be worked out
TRIAL TIME: 1 ½ days total
Government’s case including jury selection: 1 day
Defendant: ½ day
STIPULATIONS: None.
UNUSUAL QUESTIONS OF LAW: None.
FILING DEADLINES: The parties are reminded of the following pretrial filing deadlines as
originally set forth in the Scheduling and Trial Order (Doc. #26):
Witness and Exhibit Lists: Due no later than fourteen days prior to trial.
Please note: Counsel are requested to list witnesses in alphabetical order on their witness
list.
Motion in Limine: Due no later than fourteen days prior to trial.
Stipulations: Due no later than fourteen days prior to trial.
Additionally, Exhibit Index, if required by the District Court, Voir Dire, Jury
Instructions are due no later than seven days prior to trial.
Please Note: Jury instructions must comply with Local Rule 51.1
TRIAL SETTING: Criminal jury trial docket set for April 20, 2026.
Normal jury panel: Yes
Please note: The Government requests the second week of the trial docket due to witness
unavailability.
IT IS SO ORDERED.
/s/ Lajuana M. Counts
Lajuana M. Counts
United States Magistrate Judge
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