Free Motion to Shorten Time - District Court of California - California

Case 3:08-cr-02125-WQH

Document 33

Filed 08/05/2008

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Tamara D. DeHaan, Esq., 113932 LAW OFFICES OF TAMARA D. DeHAAN 444 West C Street, Suite 350 San Diego, CA 92101-3533 PH: (619) 544-0715 FAX: (619) 544-1215 Attorney for Material Witness/es

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, v. ROBERTO JAYME MEDINA, et al., Defendants.

) Crim. Case No. 08cr2125-WQH ) ) EX PARTE NOTICE OF MOTION AND ) MOTION FOR ORDER SHORTENING TIME ) ) DATE: August 7, 2008 ) TIME: 9:00 a.m. ) MAJ. JUDGE: Ruben B. Brooks ) )

TO KAREN P. HEWITT, UNITED STATES ATTORNEY, AND TO THE ATTORNEYS OF RECORD FOR THE ABOVE-NAMED DEFENDANTS: PLEASE TAKE NOTICE that on August 7, 2008, at 9:00 a.m., or as soon thereafter as counsel may be heard, material witnesses CONRADO ARTEAGA-RODRIQUEZ and JORGE ESTRADACEJA (hereinafter, "Material Witnesses") by the through their counsel, Tamara D. DeHaan, will bring a motion for an order to shorten time to file a motion to set videotaped depositions of the Material Witnesses. MOTION The Material Witnesses, by and through their counsel, Tamara D. DeHaan, Esq., and pursuant to Federal Rules of Criminal Procedure, Rules 28, 29, and 30, hereby move this court for an order shortening time for filing and serving a notice of motion and motion to take their depositions by

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Case 3:08-cr-02125-WQH

Document 33

Filed 08/05/2008

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videotape, to three (3) days, to be heard on August 7, 2008, at 9:00 a.m., or as soon thereafter as counsel may be heard. The motion for an order to shorten time is based on the fact the Material Witnesses are unable to meet any condition of bail, and have been in custody since June 9, 2008. If this motion is not heard at the earliest possible date and prior to a date with the usually required notice, the incarcerated Material Witnesses will languish in custody for an excessive period of time in contravention of their legal rights. This motion is based upon this Notice, the Declaration of Tamara D. DeHaan, Esq., the files and records in the above-entitled cause, and any and all other information that may be brought to the Court's attention prior to or during the hearing on this motion. Respectfully submitted,

DATED: 8/5/08

LAW OFFICES OF TAMARA D. DeHAAN

By:

s/Tamara D. DeHaan Tamara D. DeHaan Attorney for Material Witnesses

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Case 3:08-cr-02125-WQH

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Filed 08/05/2008

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Tamara D. DeHaan, Esq., #113932 LAW OFFICES OF TAMARA D. DeHAAN 444 West C Street, Suite 350 San Diego, CA 92101-3533 Ph: (619) 544-0715 Fax: (619) 544-1215 Attorney for Material Witness/es

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Honorable Ruben B. Brooks) UNITED STATES OF AMERICA, Plaintiff, v. ROBERTO JAYME MEDINA, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

Criminal Case No. 08cr2125-WQH DECLARATION OF SERVICE Person/s Served: Erick Guzman, Esq. Holly Hanover, Esq. And U.S. Attorney

Date of Service: August 5, 2008

Under penalty of perjury, I declare: 1. I am an attorney duly licensed to practice law in the State of California. I am admitted to

practice before the United States District Court for the Southern District of California. I am over the age of eighteen years and not a party to this action. 2. On August 5, 2008, I served the above-named person/s with the following documents:

Ex Parte Application for Order Shortening Time, Notice of Motion and Motion for Video Taped Deposition of Material Witnesses, Memorandum of Points and Authorities in Support of Motion, Declaration of Tamara D. DeHaan, Esq., in Support of Motion, and Proposed Order. 3. CM/ECF. Executed on August 7, 2008 at San Diego, California. s/Tamara D. DeHaan Tamara D. DeHaan, Esq. - Declarant Service was effected by e-filing the document with the Southern District Court via

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