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

Case 3:08-cr-00650-JM

Document 19

Filed 03/13/2008

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LINDA A. KING State Bar No. 087138 LAW OFFICES OF LINDA A. KING

2044 First Ave., Suite 200
San Diego, CA 92101-2079
(619) 233-8034 FAX (619) 233-4516

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Attorney for

Material Witnesses

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, vs. Matthew Charles Kennedy, et. al. Defendants. ) Criminal Case No.: 08CR0650J ) Magistrate Case No.: 08MJ0569
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) MOTION FOR MATERIAL WITNESS'S ) VIDEOTAPED DEPOSITION
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) DATE: March 25, 2008 ) TIME: .9:30 am ) HON.: NITA L. STORMES
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TO UNITED STATES ATTORNEY KAREN P. HEWITT OR HER REPRESENTATIVE, TO ATTORNEYS, JOHN C. ELLIS, JR.OF FEDERAL DEFENDERS FOR DEFENDANT

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LAWRENCE DOSS, JOAN KERRY BADER FOR DEFENDANT MATTHEW CHARLES KENNEDY AND SHAUN KHOJAYAN FOR DEFENDANT SANDRA BNI: NOTICE IS HEREBY GIVEN that on March 25, 2008 at 9:30 am, or as soon thereafter as the matter may be heard, in the courtroom of Honorable Stormes of this court, located at 940 Front Street, San Diego, California, 92101, Material Witnesses, by and through their attorney of record, Linda A. King, will move the court for an order authorizing the Videotaped depositions of the material witnesses.

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Case 3:08-cr-00650-JM

Document 19

Filed 03/13/2008

Page 2 of 2

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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

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Marshal'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 Marshal's Custody until the matter is concluded.
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