Opinion
No. 3:10-00260
09-13-2012
UNITED STATES OF AMERICA v. ABDIGADIR AHMED KHALIF
William J. Haynes, Jr.
Chief Judge, U.S. District Court
ABDIGADIR KHALIF'S MOTION TO WAIVE APPEARANCE AT
DEPOSITION OF ABDULLAH FARAH a/k/a GRAY GOOSE
Defendant Abdigadir Khalif, through counsel, respectfully requests that this Honorable Court excuse his presence at the deposition of Abdullah Farah a/k/a Gray Goose, scheduled for Wednesday, September 12, 2012. In support of this motion, counsel and Mr. Khalif state as follows:
1. Mr. Khalif is on pretrial release and resides in Minneapolis, Minnesota. Mr. Khalif is indigent, and travel to Nashville, Tennessee, for this deposition, would be very expensive.
2. It is anticipated that the deponent, Abdullah Farah, will refuse to testify. Thus, requiring Mr. Khalif to incur the travel expense from Minnesota to be present for this deposition will create an undue hardship on Mr. Khalif and cause him to incur unnecessary expenses under these circumstances.