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

Case 5:07-cr-00613-JF

Document 12

Filed 02/04/2008

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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: February 4, 2008 /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

Document 12

Filed 02/04/2008

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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 the state of Florida beginning on February 16, 2008 and returning to California on February 23, 2008, for the purpose of attending a 60th birthday celebration for his brother-in-law with his family and his wife's family. The specific itinerary is as follows: Depart California(San Jose Airport) 2/16/08 to Miami, Florida, local address 13627 Deering Bay Drive, Coral Gables, FL 33158 (the home of brother-in-law, Jim Mayes; telephone no. (305) 984-2613); Depart Coral Gables on 2/18/08 and drive to the Lime Tree Resort in Islamorada, Florida (Florida Keys), through 2/21/08; Return to Coral Gables for the night of 2/22/08; return to San Jose Airport on 2/23/08. 3. I have presented this request and proposed itinerary to Jaime Caranza of Pretrial Services who has indicated that defendant is in full compliance with his release conditions and that he has no objection to the requested travel. 4. I have attempted to discuss this request with AUSA Joseph Fazioli but have not been able to reach him as of the time of this filing. I declare under penalty of perjury that the foregoing is true and correct, to the best of my knowledge and belief. Executed this 4th day of February, 2008 at Woodland Hills, California.

/s/ Alan Baum ALAN BAUM

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Case 5:07-cr-00613-JF

Document 12

Filed 02/04/2008

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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: February , 2008 ___________________________ 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 February 16, 2008 and travel as follows: Depart California(San Jose Airport) 2/16/08 to Miami, Florida, local address 13627 Deering Bay Drive, Coral Gables, FL 33158 (the home of brother-in-law, Jim Mayes; telephone no. (305) 984-2613); Depart Coral Gables on 2/18/08 and drive to the Lime Tree Resort in Islamorada, Florida (Florida Keys), through 2/21/08; Return to Coral Gables for the night of 2/22/08; return to San Jose Airport on 2/23/08. All other conditions of release shall remain the same.