BY ALFONSO CHARDY

                      The Eriberto Mederos torture trial should remain in Miami because some government witnesses are
                      elderly and should not be forced to travel and because last year's Cuban spy case showed an impartial
                      jury could be seated here, the federal prosecutor said in a court filing this week.

                      Mederos recently requested that his trial be moved because he would be denied a fair jury given
                      ''deeply rooted'' anti-Castro sentiment in the exile community and ''inflammatory'' pretrial media
                      coverage.

                      In a response, Assistant U.S. Attorney Frank Tamen wrote that the spy case -- in which five Cuban
                      intelligence agents were convicted after a seven-month trial in Miami -- showed a fair jury could be
                      picked in an emotion-charged environment. Tamen also noted that pretrial coverage in the Mederos
                      case has not been as intense as in the spy case.

                      ''The government believes it will be possible to select a fair and impartial jury in Miami-Dade County,''
                      Tamen wrote.

                      Tamen also argued that moving the trial would inconvenience government witnesses who accuse
                      Mederos of having tortured them with electroshock treatment at the Havana Psychiatric Hospital
                      between 1968 and 1978.

                      Mederos has denied that the treatment was torture. He has described it as a medical procedure
                      prescribed by doctors.