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

Case 3:07-cr-03148-BTM

Document 25-2

Filed 01/31/2008

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VICTOR MANUEL TORRES 2664 Fourth Avenue San Diego, California 92103 Telephone No. (619) 232-8776 Facsimile No. (619) 232-8857 State Bar No.: 140862 Attorney for Defendant CHARMAIGNE ESPARZA

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) v. ) ) ) CHARMAIGNE ESPARZA, ) ) Defendant. ) _________________________________) UNITED STATES OF AMERICA, Case No. 07CR3148-BTM DECLARATION OF COUNSEL IN SUPPORT OF APPLICATION FOR ORDER AUTHORIZING EXTRAORDINARY INVESTIGATOR FEES (18 U.S.C. 3006A(e)(1))

I, VICTOR MANUEL TORRES, do hereby declare and state: (1) I am an Attorney duly licensed to practice law in the courts of the State of

California, the United States District Court for the Southern District of California and the United States Supreme Court; (2) I am court appointed counsel for defendant CHARMAIGNE ESPARZA in the

above-entitled Criminal matter, having been appointed pursuant to Title 18 U.S.C. Section 3006A; (3) Presently, the defendant is charged with Title 8 U.S.C. § 1324 (a)(1)(A)(iii),

Harboring and Concealing. (4) Ms. ESPARZA is requesting the court to approve an additional fifteen (15) hours of investigation time above and beyond the 9.0 hours of time permitted under the Criminal Justice Act for a total of 24 hours, at a rate of $55.00 an hour, not to exceed a total of $1325.00 for investigator fees. This investigation is to be conducted by private investigator

Case 3:07-cr-03148-BTM

Document 25-2

Filed 01/31/2008

Page 2 of 2

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Esther Sardina, License No. PI 25143, 105 West "F" Street, San Diego, California, 92101. These funds are necessary in order to perform the following investigation: a. Meetings with defendant and/or counsel for defendant; b. Telephone conferences with counsel and family of defendant; c. Locate and interview witnesses in Riverside County; d. Prepare reports and memoranda for counsel for defendant. (5) Because Ms. ESPARZA has no money to pay for this investigation, counsel

8 requests that this Court approve investigator fees in the total amount of $1325.00 so that this 9 case may be fully investigated. Without these additional funds, the representation of Ms. 10 ESPARZA would not be adequate; 11

Therefore, counsel for defendant respectfully submits to this Court that these

12 additional hours are necessary at this time in order to complete the preparation of the defense 13 in his case. 14

I declare, under the penalty of perjury, the above to be true and correct to the best of

15 my information and belief. 16 17 DATED: 18 19 20 21 22 23 24 25 26 27 28

January 21, 2008

S/ VICTOR MANUEL TORRES VICTOR MANUEL TORRES, ESQ. Declarant