Anybody have a motion and order for use immunity.

Scenario: Inmate in County Jail makes phone call to woman to set up his escape. He escapes with her help and is captured shortly therafter. Inmate and woman are both indicted for escape.

He is coming up for trial. Need to get recorded jail phone call into evidence. Nobody with law enforcment can prove up her voice. Have subpoenaed woman (who is under indictment for the escape) for the sole purpose of proving up the jail phone call. As I understand it, I can force her to testify and overcome her invocation of the 5th with use immunity.

I know it requires a motion and approval (order) of the Court. Anyone done such a motion and order?

Have you tried old employers (hahaha), people she has spoken with over at the welfare office, neighbors who hate her, old associates? There has got to be someone, maybe her mother, brother, father, friend, bondsman, jailers, arresting officers?

How about having the defendant read the transcript of the phone call out loud in front of the jury and then let the jury compare that voice with the sound on the recording?

In addition, defendant usually has to identify himself at the beginning of the call. (We recently had a defendant identify himself as "Drug Dealer.")

But, it isn't such a bad idea to have the other side of the phone call ID the voice as well. And use immunity should get the job done.

I have one and will email it to you.