Attorneys for Shaheed ‘Roger’ Khan, Diarmuid White and John Bergendahl have informed the presiding Judge Dora L. Irizarry of the United States District Court Eastern District of New York that the defence team will be limiting depositions to be taken in Guyana to two witnesses, Elizabeth Persaud and Dion Coates.According to the document that was filed on Sunday last by the two attorneys, it was following up on a letter dated February 27, 2009, given that counsel here reported that on March 6, 2009, the Ministry of Foreign Affairs declined to file with the High Court of Guyana a certificate that it has no national security or other objection to the letter rogatory,Cheap Jerseys China, until Khan provides the Ministry with a summary of each witness’s prospective testimony for its review.“The Ministry had made no such demand previously….Given the Ministry’s position, the High Court has put the matter over until March 16, 2009.”The attorneys posited that because of the imminence of the trial, the time constraints on the parties involved, and Khan’s concern that depositions in Guyana are being rendered impossible as originally intended, he proposes to limit the depositions to two witnesses, Elizabeth Persaud and Dion Coates.Their prospective testimony is aimed at contradicting the testimony of prosecution witnesses regarding material facts, “could have no colorable affect on national security issues in Guyana and who could be examined and cross-examined in a few hours, at most, since their testimony would be brief and narrowly circumscribed….Counsel proposes that these two depositions be conducted on a single day during the week of March 30, 2009.”The defence team in the document addressed to Judge Irizarry stated, “the defendant, through counsel in Guyana, is providing the Ministry of Foreign Affairs with a summary of Persaud’s and Coates’s prospective testimony, in the expectation that the Ministry will file the certificate required by the High Court on or before March 16, 2009.”This move by Khan’s attorney sparked an immediate response given that the prosecution the following day in a document addressed to Judge Irizarry stated that,Wholesale NBA Jerseys China, “The (US) government has objections and comments to the defendant’s proposal.”Firstly, the US Government renewed its objection “that the two depositions at issue do not meet the standards of Rule 15 of the Federal Rules of Criminal Procedure….While the Court has previously ruled in its June 2,Wholesale NFL Jerseys, 2008 Order that these depositions were permissible, it did so in the context of a much larger request involving several more witnesses…When the Rule 15 motion is narrowed to simply these two impeachment witnesses, the Court’s evaluation may differ,Wholesale NFL Jerseys, particularly considering the current trial schedule….Furthermore, at this point, the Court may factor into its evaluation that these depositions are untimely.”The prosecution also pointed out that the (US) government is requesting that the Court order Roger Khan to provide both the Court and the government with a copy of the summary of prospective testimony provided to Guyana’s Ministry of Foreign Affairs.The prosecution also requested that the government should have an opportunity to confirm that the representations made to Guyana about the proposed testimony are the same as those previously made to the Court in the defendant’s Rule 15 motion and during the ex parte conference on April 28, 2008 which the Court relied on in issuing its Order.The (US) Government also requested that defence counsel provide the government with any other prior statement of each defence witness in the defendant’s possession at least two business days prior to the scheduled deposition in order to avoid any unnecessary delay between the direct and cross examination of the witnesses.The government also objected to conducting the depositions on March 30, 2009, which is after jury selection has begun.“The government respectfully requests that the depositions be completed before jury selection begins…Furthermore,Wholesale Jerseys Free Shipping, the government wants to ensure that it has a full opportunity to cross-examine each defence witness.”US prosecutor Benton Campbell also pointed out in the document that while he has no intention of unnecessarily prolonging the depositions, if defence counsel attempts to cut the government off prematurely during cross-examination in order to conclude both witnesses in one day,Wholesale Jerseys, the government may be prejudiced.The prosecution also requested that defence counsel be prepared, if necessary, to conduct the depositions