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

Case 3:08-mj-00843-LSP

Document 10

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) ) ) ) Plaintiff, ) ) vs. ) ) MARTIN ORTIZ-CASTANEDA, ) ) ) ) ) Defendant. ) ______________________________) UNITED STATES OF AMERICA, CASE NO. 08MJ0843 NOTICE OF MOTION; MOTION FOR VIDEOTAPE DEPOSITION AND SUBSEQUENT VOLUNTARY DEPORTATION OF MATERIAL WITNESS; MEMORANDUM OF POINTS AND AUTHORITIES AND DECLARATION OF THOMAS G. GILMORE IN SUPPORT THEREOF DATE: April 15, 2008 TIME: 9:30 am PLACE: Courtroom of Magistrate Leo S. Papas ATTORNEYS OF

TO: UNITED STATES ATTORNEY; DEFENDANTS AND THEIR RECORD:

PLEASE TAKE NOTICE that on April 15, 2008 at 9:30 a.m. or as soon thereafter as the matter may be heard, material witnesses ADOLFO GALVEZ-DE JESUS, ALBERTANO PANTALEON-NAJERA, FRANCISCO

RAMIREZ-VELASQUEZ and ANTONIO GALVEZ-DE JESUS,

will move the Court

for an Order that they be subjected to a videotape deposition prior to trial and subsequent voluntary deportation. This motion will be based on 18 U.S.C. 3144 in that the witnesses testimony can be adequately secured by deposition and 1

Case 3:08-mj-00843-LSP

Document 10

Filed 04/02/2008

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further detention is not necessary to prevent a failure of justice. This motion is further based on this notice of motion, the memorandum of points and authorities and declaration of Thomas G. Gilmore filed herewith, and as such other and further evidence as may be presented at the hearing of the motion. Respectfully submitted, DATED: 4/2/08 /ss/Thomas G. Gilmore THOMAS G. GILMORE, Attorney for Material Witnesses

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