Stein Entry 157

7/30/2019 Stein Entry 157

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UNITED STATES DISTRICT COURT RLEDW

SOUTHERN DISTRICT OF FLO RIDA

;PR 2 j aj3UNITED STATES OF AMERICA, j

5 LTzfithnlg zlaintil, j s.o.an.x.-weav. 5 case No 11-80205-CR-

MARRA/HOPKINS

5MITCHELL J. STEIN, j

5Defendant. j

I

NOTICE OF LODGM ENT OF RULE 15 DEPOSITIONOF M R. ROW LAND PERKINS AND STATEM EM T OF PARTIES'

INTENTION RE: USE OF SUCH TM NSCRIPT AND VIDEO-TAPE

PLEASE TAKE NOTICE, that Defendant Mitchell J. Stein hereby lodges - based

upon an agreement with the Government - the original transcript and video-tape of

the Deposition of Rowland Perkins (hereinafter ''Perkins deposition'') taken in Los

Angeles, California on Septem er 21, 2012 with a1l parties present.

PLEASE TAKE FIJRTHER NOTICE that the Government has agreed that it

shall not attempt to utilize the Perkins deposition during its case in chief.

PLEASE TAKE FURTHER NOTICE that Defendant Mitchell J. Stein has agreed

that he may utilize all or portionts) of the Perkins deposition during his case in

chief, in the event the Defense is ultimately called upon to put on a case.

PLEASE TAKE FURTHER NOTICE that the Governm ent and M r. Stein have

agreed that they both wish the Court to rule on the objections set forth in the

Perkins deposition, prior to either party reading the Perkins deposition to the

july

PLEM E TAKE FURTHER NOTICE that Defendant Mitchell J. Stein has

stated his intention - in any event - to only use small portions of the Perkins

Case 9:11-cr-80205-KAM Document 157 Entered on FLSD Docket 04/30/2013 Page 1 of 5



deposition video-tape (as opposed to the deposition transcript) for the primary

purpose of dem onstrating the condition of Mr. Perkins at the tim e of the deposition.

Respectfully submitted,1

%

MITCHELL J. STEINDefendant In Propria Persona

Phone: 561-350-6136Email: private.oceibod@ gmailxcom

Address: 1551 N. Flagler Dr.W est Palm Beach, FL 33401




CERTIFICATE OF SERW CE

I HEREBY CERTIFY that a true and correct copy of the foregoing document has been

filed with the Court, and thereafter is being filed and served via electronic mail by sending a notice of

electronic filing to the following counsel of record identified in the Service List below in the manner

specified herein. 1 hereby further certify that all counsel identified above have been sent emails

containing this document.

April 29, 2016

Albert Steiglitz, Esq.Kevin B Muhlendorf, Esq.U.S. Department of Justice

Criminal Division - Fraud Section1400 New York Avenue, 41 Floor

W ashington, D.C. 20005




CERTIFICATE OF SERW CE

l HEREBY CERTIFY that a true and correct copy of the foregoing document has been

filed with the Court, and thereafter is being filed and served via electronic mail by sending a notice of

electronic filing to the following counsel of record identified in the Service List below in the manner

specified herein. I hereby further certify that al1 counsel identifsed above have been sent emails

containing this document.

April 29, 2016

Albert Steiglitz, Esq.Kevin B M uhlendorf, Esq.U.S. Department of Justice

Criminal Division - Fraud Section1400 New York Avenue, 4* Floor

Washington, D.C. 20005

V t.i h+ .




United States District Court

Southern District of Florida

// X frpzmfase Number:

SUPPLEMENTAL ATTACHMENTIS)

Please refer to supplem ental paper ''coud file'' in the division where

the Judge is cham bered. These attachm ents m ust not be placed in

the ''chron file''

Documents Retained in Supplemental Case Files (Scanned or Not Scanned)

Civil Case Docum ents* Handwritten documents/pleadings (i.e., pro se)@ Poor quality scanned images. Photographs

. CD, DVD, VHS tapes, cassette tapes

. Surety bonds

* Exhibits that cannot be scanned (e.g., objects). Bound extradition papers. Jury verdict* Jury notes (unredacted)

. Jury selection materials (seating charts, challenges, etc.)Criminal Case Docum ents

. Handwritten documents/pleadings (i.e., pro se)

. Poor quality scanned images* Photographs.CD, DVD, VHS Tape, Casse te Tapes (. l

. . Bond documentation (zJ p. pt@ Exhibits that cannot be scanned (e.g., objects). Indictm ents@ Arrest warrants* Jury verdict. Jury notes (unredacted). Jury selection materials (seating chads, challenges, etc.)

-pp vgate:

Revised: 8/20/2012
