Free Motion to Admit Videotape - District Court of California - California


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Date: November 19, 2007
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State: California
Category: District Court of California
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Case 3:07-cr-03116-LAB

Document 11

Filed 11/19/2007

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Linda A. King, Esq. SBN. 087138 LAW OFFICES OF LINDA A. KING & ASSOCIATES 2044 First Avenue, Suite 200 San Diego, California 92101-2079 Telephone: (619) 233-8034 Fax: (619) 233-4516 Attorney for Material Witnesses

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (Magistrate Judge McCurine)

UNITED STATES OF AMERICA; Plaintiff, vs.

BLANCA ESTRELLA-MORAN, Defendant.

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Criminal Case No: O7CR3116-LAB Magistrate Case No. 07MJ2461 MOTION FOR MATERIAL WITNESS'S VIDEOTAPED DEPOSITION

DATE: November 29, 2007 TIME: 9:00 am HON: William McCurine

TO UNITED STATES ATTORNEY KAREN P. HEWITT OR HER REPRESSENTATIVE AND JODI THORPE, ATTORNEY FOR DEFENDANT: NOTICE IS HEREBY GIVEN that on November 29, 2007 at 9:30.00 am, or as soon thereafter as the

matter may be heard, in the courtroom of Honorable William McCurine of this court, located at 940 Front Street, San Diego, California 92101, Material Witness, Jose Castro dela Cruz by and through their

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1 MOTION FOR MATERIAL WITNESS'S VIDEOTAPED DEPOSITION

attorney of record, Linda A. King, will move the court for an order authorizing the videotaped deposition of the material witnesses.

Case 3:07-cr-03116-LAB

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Filed 11/19/2007

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

Date: ______________________________

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S/Linda A. King __________ Linda A. King Attorney for Material Witness(es)

2 MOTION FOR MATERIAL WITNESS'S VIDEOTAPED DEPOSITION