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    Richard Allen Documents

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    MOTION FOR LEAVE OF COURT TO CONDUCT INMATE DEPOSITIONS

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    Richard Allen Documents

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    84 views2 pages

    Motion For Leave of Court To Conduct Inmate Depositions

    Uploaded by

    Matt Blac inc.
    Richard Allen Documents

    Copyright:

    Public Domain
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    of 2

    Filed: 4/11/2024 2:58 PM

    Carroll Circuit Court


    Carroll County, Indiana

    STATE OF INDIANA ) IN THE CARROLL CIRCUIT COURT


    )ss:
    COUNTY OF CARROLL ) CAUSE NO. 08C01-2210-MR—000001

    STATE OF INDIANA
    )
    VS.

    RICHARD M. ALLEN

    MOTION FOR LEAVE OF COURT TO CONDUCT INMATE DEPOSITIONS

    Comes now the Defendant, Richard M. Allen, by Counsel, Bradley A. Rozzi,


    and pursuant to Rule 30(A) of the Indiana Rules of Trial Procedure, respectfully
    requests that this Court issue an Order granting leave of Court allowing
    Defendant

    Allen's legal team to conduct depositions of inmates at the Westville Correctional


    Facility. In support of said Motion, Defendant Allen states as follows:
    l. The parties are in the process of conducting discovery by way of
    depositions in preparation for the May 13, 2024, jury trial in this cause;
    2. The State, in its Witness and Exhibit List dated March 8, 2024, has

    identified a number of Correctional Officers and Inmates that the State intends to call
    as witnesses in this cause. Most, if not all of these inmates are associated with the
    Westville Correctional Facility where Defendant Allen was housed for over a year
    before his transfer in December of 2023;

    3. The defense desires to depose one incarcerated individual, Jesse James

    (DOC# 271835);
    4. Attorney Rozzi believes that Inmate James is currently housed in the
    Westville Correctional Facility;
    5. The Westville Correctional Facility is located in a fairly remote area.

    Attorney Rozzi has attempted to secure a location to conduct said depositions in the
    HILLIS. H runs.
    ROZZI & DEAN. LLC Town of Westville, just a mile or two down the road, but has been unable to do so due
    ATTORNEYS AT LAW
    200 NUR'I'H ST. to the fact that Westville is a very small town with very few locations that are suitable
    maANsponw. 1N 40947
    (574D 722-4560
    FAX L574.) 722-2650
    for such a circumstance;

    JOHN R. Hams
    Ln. «7533-09
    BRADLEY A. Rozzr
    Ln. mazes-09
    BRADEN J. DEAN
    u). "31941-34
    6. Attorney Rozzi was able to seek out and secure a space at the LaPorte
    County Shen'ff' s Department in LaPorte, Indiana, approximately twenty (20) miles
    fiom Westville Correctional Facility. This is the closest and most accommodating
    location where Attorney Rozzi was able to secure an adequate space to conduct

    depositions of the above referenced inmate and other prison employees not referenced
    in this pleading;
    7. Attorney Rozzi respectfully requests that this Court issue an Order granting
    his request to conduct depositions of Inmate James;
    8. Attorney Rozzi has made arrangements for said depositions to occur at the
    Laporte County Sheriff's Department on Thursday, April 18, 2024, commencing at
    8:00 a.m. (CST) at which time Attorney Rozzi desires to depose Inmate James; and
    9. Attorney Rozzi requests that this Court issue an Order granting leave of
    Court and directing the Indiana Department of Corrections to transport Inmate Jesse
    James (DOC# 271835) to said deposition and thereafter, return Jesse James to his

    respective location of incarceration.

    Respectfilll bmltted

    /
    33' R0 3365 9

    /3r S, HI ROZZ DEAN

    CERTIFICATE OF SERVICE
    I certify that I have served a copy of this docume y the County e-filing
    system upon the Carroll County Prosecutor's Office . dwin the 11th
    day of April, 2024.

    I-IILLIS. HILLIS.
    Rozzx & DEAN. LLC
    ATTORNEYS AT LAW
    200 FOURTH ST.
    radley A. R0 ', #2 65-09
    LDGANSI'()RT, 1N 46947 HIL , LIS ZZI & DEAN
    (574) 72m0
    FAX (570 722-2659
    200 F0 et
    Logansport, IN 46947
    JOHN R. HILLls
    LD. «7533-09 574-722-4560
    BRADLEY A. Rozzx
    Ln. #2336509
    BRADEN J. DEAN
    LD. "31941-34

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