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

Case 3:07-mj-02966-LSP

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Filed 01/03/2008

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WAYNE C. MAYER (62031) Law Offices of Wayne C. Mayer 4619 Van Dyke Avenue San Diego, CA 92116 (619) 281-9263 fax (619) 281-2963 Attorney for Material Witness: MIRTA LUNA PORTILLO HECTOR GUZMAN GARCIA JAIME ANTONIO PRECIADO GARCIA

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

) ) ) Plaintiff, ) ) vs. ) SERGIO PRECIADO DIAZ; CONCEPCION ) ) GARCIA OROZCO, ) ) Defendants. UNITED STATES OF AMERICA,

Case No.: 07 MJ 2966 NOTICE OF MOTION AND MOTION FOR VIDEOTAPE DEPOSITION OF MATERIAL WITNESSES MIRTA LUNA PORTILLO, HECTOR GUZMAN GARCIA, JAIME ANTONIO PRECIADO GARCIA AND REQUEST FOR STATEMENT OF REASONS IN SUPPORT OF CUSTODY DATE: 1/22/08 TIME: 9:30 a.m. DEPT: Magistrate Papas

PLEASE TAKE NOTICE that on January 22, 2008 at 9:30 a.m. or as soon thereafter as counsel may be heard, material witness MIRTA LUNA PORTILLO, HECTOR GUZMAN GARCIA and JAIME ANTONIO PRECIADO GARCIA (hereafter "Material Witnesses") by and through his counsel, Wayne C. Mayer will bring a motion for a court order to take the Material Witnesses' videotaped deposition.

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Case 3:07-mj-02966-LSP

Document 7

Filed 01/03/2008

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MOTION Material Witnesses, pursuant to Federal Rules of Criminal Procedure, Rule 15, and Title 18 U.S.C. sec. 3144, hereby moves this court for an order to take their deposition by videotape and release them at the conclusion of the deposition. If the Court denies this motion, then Material Witnesses further requests the United States Attorney's office provide the witnesses

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with a Statement of Reasons in Support of Custody in accordance with Federal Rules of Criminal
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Procedure, Rule 46(g).
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This Motion is based upon this Notice, the Memorandum of Points and Authorities in Support thereof, the Declaration of Wayne C. Mayer, the files and records in the above entitled cause, and any and all other information brought to the Court's attention prior to or during the hearing on this motion. Dated: January 3, 2008 Respectfully submitted,

____________________________________ Wayne C. Mayer Attorney for Material Witnesses MIRTA LUNA PORTILLO, HECTOR GUZMAN GARCIA JAIME ANTONIO PRECIADO GARCIA

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07 MJ 2966