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

Case 3:07-cr-03128-H

Document 6

Filed 11/05/2007

Page 1 of 1

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 GUADALUPE ESQUIVEL-GARCIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, vs. Juan Francisco AGUAYO

Defendant(s)

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

Case No. 07mj2500 (WMc) APPLICATION SHORTENING TIME TO HEAR THE MOTION TO CONDUCT A VIDEOTAPE DEPOSITION OF MATERIAL WITNESS GUADALUPE ESQUIVELGARCIA DATE: November 15, 2007 TIME: 9:30 a.m. JUDGE: Honorable William McCurine, Jr.

I, Ray Keramati, attorney for material witness GUADALUPE ESQUIVEL-GARCIA submit this ex parte application to shorten the amount of notice required to hear the motion of the Material Witness to take her videotape deposition. This application is made on behalf of the Material Witness, who is unable to locate anyone to pay her court appearance bond and immigration bond, she has not been charged with any crime, and her further detention would impose an undue hardship on her and her family.

DATED: November 5, 2007

/s/ Reza Keramati________________ R. Keramati, Esq. Attorney for Material Witness

-1APPLICATION SHORTENING TIME TO HEAR THE MOTION TO CONDUCT A VIDEOTAPE DEPOSITION OF MATERIAL WITNESS GUADALUPE ESQUIVEL-GARCIA