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

Case 3:08-mj-00843-LSP

Document 10-2

Filed 04/02/2008

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THOMAS G. GILMORE, ESQ. State Bar No. 91984 LAW OFFICES OF THOMAS G. GILMORE 3232 FOURTH AVENUE SAN DIEGO, CALIFORNIA 92103 (619) 426-4444 Attorney for Material Witnesses

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Honorable Leo S. Papas) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) vs. ) ) MARTIN ORTIZ-CASTANEDA, ) ) ) ) Defendant. ) _______________________________) I, Thomas G. Gilmore declare: I am an attorney duly licensed to practice before all the courts of this State, District and Circuit, and am the attorney of record for the material witnesses in the above action, ADOLFO CASE NO. 08MJ0843

DECLARATION OF THOMAS G. GILMORE IN SUPPORT OF MOTION FOR VIDEOTAPE DEPOSITION AND SUBSEQUENT VOLUNTARY DEPORTATION OF MATERIAL WITNESSES DATE: April 15, 2008 TIME: 9:30 a.m. PLACE: Courtroom of Magistrate Leo S. Papas

GALVEZ-DE JESUS, ALBERTANO PANTALEON-NAJERA, FRANCISCO RAMIREZVELASQUEZ and ANTONIO GALVEZ-DE JESUS. I have personal knowledge of the facts set forth in this action and could testify competently thereto if called. My clients in this action have been in federal custody since March 15, 2008 because they cannot locate anyone to post bond for them. 1

Case 3:08-mj-00843-LSP

Document 10-2

Filed 04/02/2008

Page 2 of 2

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My clients entered the United States to find work to support family members at home in their country of origin. Each day they

remain in custody is an additional hardship on themselves and their families. Based on the above it respectfully requested that this motion granted, that said depositions take place at the earliest

possible time, and that my clients be allowed to voluntarily return home to their country of origin immediately thereafter. I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct of my own personal knowledge except as to those matters stated to be based upon information and belief and, as to those matters, I am informed and believe that they are true and correct. Executed this 2nd day of April, 2008, in San Diego, California. /ss/ Thomas G. Gilmore THOMAS G. GILMORE, Attorney for Material Witnesses

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