UNITED STATES DISTRICT COURT RLEDW
SOUTHERN DISTRICT OF FLORIDA
;PR 2 j aj3
UNITED STATES OF AMERICA, j
aintil, j s.o.an.x.-w
v. 5 case No 11-80205-CR-
MITCHELL J. STEIN, j
INOTICE OF LODGMENT OF RULE 15 DEPOSITIONOF MR. ROWLAND PERKINS AND STATEMEMT OF PARTIES'INTENTION RE: USE OF SUCH TMNSCRIPT 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 Septemer 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 Government and Mr. 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
PLEME 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