Free Motion to Admit Videotape - District Court of California - California


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Date: April 11, 2008
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State: California
Category: District Court of California
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Case 3:08-cr-00972-WQH

Document 15

Filed 04/11/2008

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Linda A. King, Esq. SBN. 087138 LAW OFFICES OF LINDA A. KING & ASSOCIATES 2044 First Avenue, Suite 200 San Diego, California 92101-2079 Telephone: (619) 233-8034 Fax: (619) 233-4516 Attorney for Material Witnesses

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Magistrate Judge McCurine, Jr.)

UNITED STATES OF AMERICA; Plaintiff, vs.

RAMON VASQUEZ-CABRALES, et al. Defendant.

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Criminal Case No: 08cr0972 Magistrate Case No. 08mj0942 MOTION FOR MATERIAL WITNESSES' VIDEOTAPED DEPOSITION

DATE: April 29, 2008 TIME: 10:30 am HON: William McCurine, Jr.

TO UNITED STATES ATTORNEY KAREN P. HEWITT OR HER REPRESSENTATIVE, TO ATTORNEY, FEDERAL DEFENDERS FOR DEFENDANT (name of defendant): NOTICE IS HEREBY GIVEN that on April 29, 2008 at 10:30 am, or as soon thereafter as the matter may be heard, in the

courtroom of Honorable William McCurine, Jr. of this court, located at 940 Front Street, San Diego, California 92101, Material Witnesses Eduardo Reyes-Rodriguez and Ramon Torres-Silva by and through

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1 MOTION FOR MATERIAL WITNESS'S VIDEOTAPED DEPOSITION

their attorney of record, Linda A. King, will move the court for an order authorizing the videotaped deposition of the material witnesses.

Case 3:08-cr-00972-WQH

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Filed 04/11/2008

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The motion will be made on the ground that there is good cause for the order requested in that the material witnesses know of no sureties in this country who will bond them out of US Marshall's Custody during the pendency of this matter. Neither the interests of justice nor the convenience of the parties and witnesses will be served by requiring the material witnesses to remain in Marshall's Custody until the matter is concluded.

Date:April 10, 2008 S/Linda A. King __________ Linda A. King Attorney for Material Witness(es)

2 MOTION FOR MATERIAL WITNESS'S VIDEOTAPED DEPOSITION