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

Case 5:07-cr-00613-JF

Document 4

Filed 10/23/2007

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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: October 23, 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 10/23/2007

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1 DECLARATION OF ALAN BAUM 2 Alan Baum, being first duly sworn, does declare and state: 3 1. I am the attorney of record for the Defendant herein and state the following based upon 4 my own personal knowledge and upon information and belief. I file this declaration in support of 5 defendant's request for a court order allowing him to travel out of the state of California, as set forth 6 in greater detail herein. 7 2. Defendant desires to travel to Las Vegas, Nevada to attend a birthday party for his brother. 8 Defendant intends, if allowed, to leave San Jose airport and to fly to Las Vegas on Saturday, 9 November 3, 2007. He will be staying at the Stratosphere Towers Hotel, 2000 Las Vegas Blvd. 10 South. The hotel's telephone number is (888) 212-0093. Defendant plans on returning to San Jose 11 on Sunday, November 4, 2007. The party for his brother will be at the Bellagio Hotel in Las Vegas 12 on Saturday, November 3, 2007. 13 3. I have presented this request and proposed itinerary to Laura Weigel of Pretrial Services 14 and she has indicated that she has no objection to the requested travel. I have been trying to reach 15 the AUSA on this case, Joseph Fazioli, but have not spoken with him. 16 I declare under penalty of perjury that the foregoing is true and correct, to the best of my 17 knowledge and belief. 18 Executed this 23nd day of October, 2007 at Woodland Hills, California. 19 20 21 22 /s/ Alan Baum 23 ALAN BAUM 24 25 26 27 28 2

Case 5:07-cr-00613-JF

Document 4

Filed 10/23/2007

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1 (PROPOSED) ORDER 2 Upon application by the defendant and good cause appearing therefore, IT IS HEREBY 3 ORDERED that defendant is permitted by the Court to travel out of the State of California, as 4 follows 5 Defendant may leave San Jose airport and fly to Las Vegas on Saturday, November 3, 2007. 6 He may stay at the Stratosphere Towers Hotel, 2000 Las Vegas Blvd. South. The hotel's telephone 7 number is (888) 212-0093. Defendant shall return to San Jose on Sunday, November 4, 2007. The 8 defendant may attend the party for his brother at the Bellagio Hotel in Las Vegas on Saturday, 9 November 3, 2007. 10 All other conditions of release shall remain the same. 11 12 13 Dated: October 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 , 2007 ___________________________ RICHARD SEEBORG United States Magistrate Judge