Free Certificate of Service - District Court of California - California

Case 3:08-cr-02430-BTM

Document 27

Filed 08/08/2008

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1 KAREN M. STEVENS

California Bar No. 110009 2 185 W. F Street, Suite 100 San Diego, California 92101 3 Telephone: (619) 239-8553 Facsimile: (619) 239-0056 4 [email protected]
5 Attorney for Gerardo Salto-Rocha 6 7

UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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(HONORABLE BARRY TED MOSKOWITZ)
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UNITED STATES OF AMERICA,
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Plaintiff,
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v.
13 14 GERARDO SALTO-ROCHA (1),

JOSE HERNANDEZ-RIVAS)(2)
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Defendants. TO:

) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 08CR2430-1-BTM Date: August 15, 2008 Time: 2:30 p.m. NOTICE OF OPPOSITION AND OPPOSITION TO MOTION FOR VIDEOTAPED DEPOSITION OF MATERIAL WITNESSES

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KAREN P. HEWITT, UNITED STATES ATTORNEY, and PETER MAZZA, ASSISTANT UNITED STATES ATTORNEY GAYLE MAYFIELD-VENIERIS, MATERIAL WITNESS ATTORNEY: PLEASE TAKE NOTICE that on August 15, 2008, at 2:30 p.m., or as soon

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thereafter as counsel may be heard, the defendant, Gerardo Salto-Rocha,
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by and through his attorney, Karen M. Stevens will ask this Court to deny
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the pending motion for a videotaped deposition of the material witnesses.
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//
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MOTIONS
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Gerardo Salto-Rocha, by and through his attorney, pursuant to the
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Amendments to the United States Constitution, Federal Rules of Criminal
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Procedure, and all other applicable statutes, case law and local rules,
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Case 3:08-cr-02430-BTM

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Filed 08/08/2008

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1 hereby moves this Court for an order: 2 3

Denying Motions For Videotaped Depositions This opposition is based upon the instant opposition and notice of

4 opposition, the attached statement of facts and memorandum of points and 5 authorities, and any and all other materials

that may come to this

6 Court's attention at the time of the hearing on this motion. 7 8 9 Dated: August 8, 2008 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted, /s/ Karen M. Stevens KAREN M. STEVENS Attorney for Gerardo Salto-Rocha

08CR2430BTM

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Case 3:08-cr-02430-BTM

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PROOF OF SERVICE I, the undersigned, declare that:

1. I am over eighteen (18) years of age; am a resident of the County of San Diego, State of California; and my business address is 185 W.F. 4 Street, Suite 100, San Diego, California, 92101. 2. I am effecting service of DEFENDANT'S MOTIONS on the following parties by electronically filing the foregoing with the Clerk of the 6 District Court using its ECF System, which electronically notifies them:
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PETER MAZZA, Assistant U.S. Attorney Office of the U.S. Attorney 880 Front Street San Diego, CA 92101 DAVID BAKER 419 19TH Street San Diego, CA 921022 GAYLE MAYFIELD-VENIERIS 462 Stevens Aveenue, Suite 303 Solana Beach, CA 92075 I hereby certify that I have mailed the foregoing, by United States Postal Service to the following non-EFC participants in this case: 1. N/A

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to the last known address, at which place there is delivery service of 17 mail from the United States Postal Service.
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I declare under penalty of perjury that the foregoing is true and correct. Executed on August 8, 2008

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S/Karen M. Stevens 21 KAREN M. STEVENS
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08CR2430BTM

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