Free Motion for Release of Material Witness - District Court of California - California

Case 3:08-cr-01455-BEN

Document 45

Filed 06/27/2008

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NED LYNCH--Cal. St. Bar No. 149680 Attorney at Law 110 West C Street, Suite 1407 San Diego, CA 92101 Telephone: 619-525-0081 Attorney for the Material Witness(es)

United States District Court Southern District of California (Hon. Roger T. Benitez) ) ) Plaintiff, ) ) v. ) ) ARA E. AVETYANTS, ASHOT BARSEGIAN,) and ARSEN GRISHAI MOTIVOSYAN, ) ) Defendants. ) ) UNITED STATES OF AMERICA, Criminal Case No. 08CR1455BEN(NLS) Stipulation And Joint Motion For The Release Of A Material Witness

Stipulation Ara Hakobyan is being detained as a material witness pursuant to 18 USC § 3144, and the parties agree the testimony of that witness has been adequately secured by a videotaped deposition, that further detention of this witness is unnecessary, and that it would not cause a failure of justice to release this material witness at this time. Joint Motion Plaintiff United States of America, through its counsel, United States Attorney Karen P. Hewitt and Assistant United States Attorney Rebecca S. Kanter, and Defendant Ara E. Avetyants through his counsel, Attorney Garo B. Ghazarian, and Defendant Ashot Barsegian through his counsel, Attorney Kristin J. Kraus, and Defendant Arsen Grishai Motivosyan, through his counsel,

Case 3:08-cr-01455-BEN

Document 45

Filed 06/27/2008

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Attorney Jodi D. Thorp, and Material Witness Ara Hakobyan, through his counsel, Attorney Ned Lynch, jointly move the court to immediately release Material Witness Ara Hakobyan from custody of the United States Marshal so he may be permitted to return to his home country.

Dated: June 27, 2008

s/Ned Lynch Ned Lynch, Attorney for the Material Witnesses

E-mail: [email protected]

Dated: June 27, 2008

s/Rebecca S. Kanter

Rebecca S. Kanter, Assistant U.S. Attorney E-mail: [email protected]

Dated: June 27, 2008

s/Garo B. Ghazarian

Garo B. Ghazarian, attorney for Defendant Ara E. Avetyants E-mail: [email protected]
Dated: June 27, 2008 s/Kristin J. Kraus

Kristin J. Kraus, attorney for Defendant Ashot Barsegian E-mail: [email protected]
Dated: June 27, 2008 s/Jodi D. Thorp

Jodi D. Thorp, attorney for Defendant Arsen Grishai Motivosyan E-mail: [email protected]

Stipulation and Joint Motion to Release a Material Witness U.S. v. Ara E. Avetyants, et al., Crim. Case No. 08CR1455BEN

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