Free Motion for Ex Parte Application - District Court of California - California

Case 5:07-cr-00613-JF

Document 8

Filed 12/14/2007

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1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 FOR THE NORTHERN DISTRICT OF CALIFORNIA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 DATED: December 14, 2007 /s/ Alan Baum ALAN BAUM Attorney for Defendant Defendant, by and through her attorney of record, Alan Baum, hereby applies, ex-parte, for an order allowing him to travel out of the State of California, as set forth in detail in the attached Declaration of Alan Baum ) ) ) Plaintiff, ) ) vs. ) ) CHRISTOPHER BURT WILTSEE ) ) Defendant. ) ____________________________________ ) UNITED STATES OF AMERICA CASE NO. CR 07-00613 EX-PARTE APPLICATION FOR ORDER ALLOWING DEFENDANT TO TRAVEL OUT OF THE STATE OF CALIFORNIA; DECLARATION OF ALAN BAUM; (PROPOSED) ORDER

Case 5:07-cr-00613-JF

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Filed 12/14/2007

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DECLARATION OF ALAN BAUM Alan Baum, being first duly sworn, does declare and state: 1. I am the attorney of record for the Defendant herein and state the following based upon my own personal knowledge and upon information and belief. I file this declaration in support of defendant's request for a court order allowing him to travel out of the state of California, as set forth in greater detail herein. 2. Defendant desires to travel to New Jersey, Virginia and Massachusetts beginning on December 23, 2007 and returning to California on January 3, 2008, for the purpose of attending family holiday parties with his family and his wife's family. The specific itinerary is as follows: Depart California 12/23/07 to Basking Ridge, New Jersey; local address 20 Hunter Lane, Basking Ridge, NJ 07920; Depart Basking Ridge 12/26/07 to Alexandria, VA; local address 6151 Cilantro, Alexandria, VA 22310; Depart Alexandria 12/29/07 to Concord, MA; local address 100 Newbury Court, Concord, MA 01742; Depart Concord 12/31/07 to Basking Ridge, NJ, same local address as above; Return to California 1/3/08. 3. I have presented this request and proposed itinerary to Laura Weigel of Pretrial Services who has indicated that she has no objection to the requested travel. Ms. Weigel has discussed with both the defendant and his wife who will be attending theses family events and has been assured that there will be no minor children present at any of them. Ms. Weigel has discussed this request with AUSA Joseph Fazioli who has indicated that the government has no objection to the requested travel I declare under penalty of perjury that the foregoing is true and correct, to the best of my knowledge and belief. Executed this 14th day of December, 2007 at Woodland Hills, California.

/s/ Alan Baum ALAN BAUM 2

Case 5:07-cr-00613-JF

Document 8

Filed 12/14/2007

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 Dated: December , 2007 ___________________________ RICHARD SEEBORG United States Magistrate Judge (PROPOSED) ORDER Upon application by the defendant and good cause appearing therefore, IT IS HEREBY ORDERED that defendant is permitted by the Court to travel out of the State of California, as follows Defendant may leave California on December 23, 2007 and travel as follows: Depart California 12/23/07 to Basking Ridge, New Jersey; local address 20 Hunter Lane, Basking Ridge, NJ 07920; Depart Basking Ridge 12/26/07 to Alexandria, VA; local address 6151 Cilantro, Alexandria, VA 22310; Depart Alexandria 12/29/07 to Concord, MA; local address 100 Newbury Court, Concord, MA 01742; Depart Concord 12/31/07 to Basking Ridge, NJ, same local address as above; Return to California 1/3/08. All other conditions of release shall remain the same.