Free Motion to Take Deposition - District Court of California - California

Case 3:08-cr-01455-BEN

Document 24

Filed 05/18/2008

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NED LYNCH--CA 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

United States District Court Southern District of California (Hon. Nita L. Stormes) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) ARA E. AVETYANTS, ASHOT BARSEGIAN,) and ARSEN GRISHAI MOTIVOSYAN, ) ) Defendant(s). ) ) Criminal Case No. 08CR1455BEN(NLS) Notice Of Motion And Motion To Take The Videotaped Deposition Of A Material Witness And Thereafter Release Him From Custody Date: June 12, 2008 Time: 9:30 a.m. Judge: Nita L. Stormes Room: F

Notice Of Hearing On June 12, 2008 at 9:30 a.m., or as soon thereafter as counsel may be heard, material witness Ara Hakobyan [the "Material Witness"] by and through his counsel, Attorney Ned Lynch, will bring a motion for a court order to conduct videotaped deposition of the Material Witness. This motion will be heard by Hon. Nita L. Stormes in Courtroom F of the U.S. District Court for the Southern District of California. Motion The Material Witness, by and through his counsel, Ned Lynch, and pursuant to Federal Rules of Criminal Procedure 15 and 18 U.S.C. § 3144, move this court for an order to take his videotaped deposition and thereafter release him from custody at the conclusion of the deposition for his return to his home country.

Case 3:08-cr-01455-BEN

Document 24

Filed 05/18/2008

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This motion is based upon this notice, the memorandum of points and authorities filed in support of this motion, the declaration of Attorney Ned Lynch, the files and records in the cases noted above, and any and all other evidence and arguments that may be brought to the court's attention prior to or during the hearing on this motion.

Dated: May 18, 2008

s/Ned Lynch Ned Lynch, attorney for the Material Witness E-mail: [email protected]

U.S. v. Ara E. Avetyants, et al., Case No. 08CR1455BEN Material Witness' Motion for Videotaped Deposition

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