[PROPOSED] COURT ORDER TO TRANSPORT DEFENDANT TERRILYNN McCAIN FOR DEPOSITION OF WITNESS BUD GRAFIUS

TROY L. NUNLEY, District Judge.

The United States of America, by and through its undersigned counsel, respectfully requests that this Court issue a written order confirming its previous order granting the Government's request pursuant to Fed. R. Crim. P. 15 (a) (1) to take the deposition of Charles "Bud" Grafius.

Subsequent to the granting of the Government's motion at a hearing on February 5, 2015, its undersigned counsel spoke with the United States Marshal's Service via telephone regarding the transportation of defendant McCain to the location where the deposition of the witness would occur. For security reasons, the United States Marshal's Service requested that the court issue an order without announcing the specific time and location of the deposition. For this reason, the Government respectful requests that the court issue the following attached Proposed Order.

ORDER

The Court, having previously heard arguments relating to the Government's motion to take the deposition of Charles "Bud" Grafius pursuant to Fed. R. Crim. P. 15 (a) (1), hereby ORDER the United States Marshal's Service to transport defendant Terrilyn McCain at a time and place to be determined by the United States Attorney's Office for the purpose of taking the deposition of a witness subpoenaed by the Government in this case. Upon completion of the deposition, the United States Marshal's service shall then return defendant Terrilyn McCain to Sacramento County Jail.

IT IS SO ORDERED.