Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 2585-2

Filed 06/20/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. RUDY CABRERA SABLAN, et al. Defendant. ______________________________________________________________________________ AFFIDAVIT OF DONALD M. THOMAS ______________________________________________________________________________ Your Affiant, Donald M. Thomas, is employed as a legal investigator and owner of Quest Investigations and Legal Services, Inc., with an office in Arvada, Colorado. I have been employed as a legal investigator for the past seventeen years. Prior to that, I was a U.S. Probation and Parole Officer in Miami, Florida and Colorado for 26 years. My firm, Quest Investigations and Legal Services, Inc., conducts primarily criminal defense investigations with an emphasis on homicide and death penalty litigation. I have been working in this case since early 2001. I support the motion for release of jury information from William Sablan's trial. I believe we need to interview the jurors as soon as possible. Interviews of jurors from William Sablan's trial would assist the defense team in focusing the issues, investigation and trial preparation in Rudy's case. This is an important resource which must be utilized, in my opinion, to comply with Mr. Sablan's right to effective assistance of counsel in this capital case. Any contact with the jurors will be conducted in a respectful and appropriate manner.

Case 1:00-cr-00531-WYD

Document 2585-2

Filed 06/20/2007

Page 2 of 2

I hereby swear and affirm that the foregoing statement is true and correct to the best of my knowledge and belief. Dated this 20th day of June, 2007.

s/Donald M. Thomas Donald M. Thomas STATE OF COLORADO City and County of Denver ) ) ss. )

Subscribed and sworn to before me by Donald M. Thomas on this 20th day of June, 2007. My commission expires 4/18/2010.

s/Polly Ashley Notary Public