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

Case 3:08-cr-01278-DMS

Document 11

Filed 04/29/2008

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NED LYNCH--CA ST. BAR NO. 149680 Attorney At Law 110 West C Street, Suite 1407 San Diego, CA 92101 Telephone: 619-525-0081 Attorney for the Material Witness

United States District Court Southern District of California (Hon. Peter C. Lewis) UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM NAVARRO, and ENRIQUE GOMEZ, Defendant(s). ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08CR1278DMS(PCL) Notice Of Motion And Motion To Take The Videotape Deposition Of A Material Witness And Thereafter Release Him From Custody Date: May 13, 2008 Time: 1:30 p.m. Judge: Peter C. Lewis Room: El Centro

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Notice Of Hearing On May 13, 2008 at 1:30 p.m., or as soon thereafter as counsel may be heard, material witness Jorge Arrellano [the "Material Witness"] by and through his counsel, attorney Ned Lynch, will bring a motion for a court order to conduct the videotaped deposition of the Material Witness and thereafter release him from custody. This motion will be heard by Magistrate Judge Peter C. Lewis in the El Centro, California courtroom of the U.S. District Court for the Southern District of California. The parties are further notified that if they oppose this motion, in addition to filing opposition papers, they can make arrangements for a telephonic appearance, although it may be necessary to agree to waiver of the appearance of the defendant for a telephonic appearance.

Case 3:08-cr-01278-DMS

Document 11

Filed 04/29/2008

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U.S. v. William Navarro, et al., Crim. Case No. 08CR1278 Mat Wit's Motion for Videotaped Deposition

Motion The Material Witness, by and through his counsel, attorney Ned Lynch, and pursuant to Federal Rules of Criminal Procedure 15 and 18 U.S.C. § 3144, move this court for an order to take his videotaped deposition and thereafter release him from custody at the conclusion of the deposition for his return to his home country. This motion is based upon this notice, the memorandum of points and authorities filed in support of this motion, the declaration of attorney Ned Lynch, the files and records in the case noted above, and any and all other evidence and arguments that may be brought to the court's attention prior to or during the hearing on this motion.

Dated: April 29, 2008

s/Ned Lynch Ned Lynch, Attorney for the Material Witness E-mail: [email protected]

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