Free Motion to Shorten Time - District Court of California - California

Case 2:07-mj-08951-PCL

Document 7

Filed 01/15/2008

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JAMES C. ALVORD, Esq. 405 South Main Street Suite B Fallbrook, CA 92028 (760) 728-1960 Attorney State Bar No. 147148 Attorney for Material Witness: JOSE JESUS LARA-RENTERIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

) ) ) Plaintiff, ) ) ) ) v. ) ) ) ) LUIS ENRIQUE GARZA , ) ) ) ) ) Defendant. ) ) ______________________________) TO: TO:

UNITED STATES OF AMERICA,

Criminal Case No.

O7cr3351-IEG

MOTION TO SHORTEN TIME AND ORDER THEREON

DATE: January 22, 2008 TIME: 2:30 pm COURT: Hon. Jan M. Adler San Diego, California

CAREY GORDEN, ESQ., Attorney for Defendant WILLIAM HALL, AUSA,Attorney for the Prosecution. MOTION

The material witness, JOSE JESUS LARA-RENTERIA, by and through his counsel, JAMES C. ALVORD, moves this Court for an Order shortening time relating to his motion, for filing and serving notice of the motion for an Order that the deposition of this material witness be taken pursuant to Rules 28, 29, and 30, of the

Case 2:07-mj-08951-PCL

Document 7

Filed 01/15/2008

Page 2 of 2

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Federal Rules of Criminal Procedure, to be heard Tuesday, January 22, 2008, at 2:30pm, or as soon thereafter as counsel may be heard, for the following reasons: The material witness is unable to meet any condition of bail, and has been in custody since November 27, 2007. If the motion is

not heard at the earliest possible date, and prior to a date within the usually required notice period, the incarcerated material witness will remain in custody for an unnecessarily excessive period of time in that his testimony could otherwise be secured by deposition, thereby saving much hardship on the witness and his family. Counsel for the Defendant and the Government have both been notified of Attorney's Alvord's intention to bring the motion for the video deposition of his client. DATED: January 22, 2008 ______________________________ JAMES C. ALVORD, ESQ. Attorney for Material Witness

IT IS SO ORDERED 20 DATED: 21 22 23 24 25 26 27 28 2 _______________________________ UNITED STATES MAGISTRATE JUDGE