Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:08-cr-00640-IEG

Document 14

Filed 03/21/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

R. Keramati, SBN# 182425 Western Legal Group, APC. 110 West C. Street, Suite 1300 San Diego, California 92101 Telephone (619) 231-2529 Facsimile (619) 231-2528 Attorney for: TOMAS IGNACIO-SANTIAGO

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE NITA L. STORMES)

UNITED STATES OF AMERICA, Plaintiff, vs. Arael GUZMAN-Rodriguez (1), Misael GARCIA-Leon (2) Defendant(s)

) ) ) ) ) ) ) ) ) ) ) ) ) )

Criminal Case No. 08cr640-IEG (NLS) NOTICE OF MOTION AND MOTION FOR THE TAKING OF A VIDEO DEPOSITION OF MATERIAL WITNESS TOMAS IGNACIO-SANTIAGO DATE: April 8, 2008 TIME: 9:30 a.m. JUDGE: Honorable Nita L. Stormes

TO: NANCY BRYN ROSENFELD, ESQ., Attorney for Defendant Arael GuzmanRodriguez TO: KRISTIN JOSEPH KRAUS, ESQ., Attorney for Defendant Misael Garcia-Leon TO: PAUL L. STARITA, AUSA, Attorney for the Prosecution. PLEASE TAKE NOTICE that on April 8, 2008 at 9:30 a.m., or as soon thereafter as counsel may be heard, in the Courtroom of the Honorable Nita L. Stormes, the material witness, TOMAS IGNACIO-SANTIAGO, by and through his counsel, RAY KERAMATI, will bring the above entitled motion. /////

-1-

08CR640-IEG (NLS)

NOTICE OF MOTION AND MOTION FOR THE TAKING OF A VIDEO DEPOSITION OF MATERIAL WITNESS TOMAS IGNACIO-SANTIAGO

Case 3:08-cr-00640-IEG

Document 14

Filed 03/21/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11

MOTION The material witness, TOMAS IGNACIO-SANTIAGO, by and through his counsel, RAY KERAMATI, and pursuant to Rule 15(a) of the Federal Rules of Criminal Procedure, and pursuant to 18 U.S.C. Section 3144, move for an order to secure his testimony pending trial, and for an order for his release from custody immediately thereafter. This motion will be made on the grounds that the witness is unable to meet any condition of release and that his testimony can be adequately be secured by deposition, and that further detention is not necessary to prevent a failure of justice and would, in fact, perpetuate an extreme hardship on the material witness and his family. This motion will be made based upon the Declaration of Ray Keramati, Esq., the Points

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -208CR640-IEG (NLS)

and Authorities in Support of the Motion, and all documents and records on file herein and upon such oral testimony as the Court may deem proper.

DATED: March 21, 2008

/s/ Ray Keramati R. Keramati, Esq. Attorney for Material Witness TOMAS IGNACIO-SANTIAGO

NOTICE OF MOTION AND MOTION FOR THE TAKING OF A VIDEO DEPOSITION OF MATERIAL WITNESS TOMAS IGNACIO-SANTIAGO