Free Motion to Travel - District Court of California - California

Case 4:07-mj-70574-MRGD

Document 37

Filed 01/17/2008

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P IE R 5 L A W O F F IC E S 506 B R O A D W AY SAN FR AN C ISC O (415) 986-5591 FAX : (415) 421-1331

RANDOLPH E. DAAR #88195 ANNE MARIE TOMASSINI #239017 506 Broadway San Francisco CA 94133 Telephone: 415/986-5591 Attorney for Defendant JESSICA SANDERS

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA, Plaintiff, v. JESSICA SANDERS, et al., Defendants. / COMES NOW defendant JESSICA SANDERS, through counsel, and hereby requests that she be allowed to travel outside of the Northern and Eastern Districts of California to South Lake Tahoe, Nevada. In support of said request, counsel declares: CR 07-70574 WDB EX PARTE REQUEST FOR TRAVEL ORDER

I am an attorney licensed to practice in the State of California and before this Court. I am one of the attorneys of

record for defendant JESSICA SANDERS. Defendant will be traveling from California to South Lake Tahoe, Nevada on Saturday, February 9, 2008, to make use of the timeshare she purchased prior to her arrest before it expires. She will be staying at Zephyr Cove, a condominium complex, located at 180 Elk Point Road, South Lake Tahoe, Nevada, 89448, 1

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Case 4:07-mj-70574-MRGD

Document 37

Filed 01/17/2008

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P IE R 5 L A W O F F IC E S 506 B R O A D W AY SAN FR AN C ISC O (415) 986-5591 FAX : (415) 421-1331

telephone number (775) 588-2388.

She will returning to

California on Sunday, February 10, 2008. My associate has discussed this matter with United States Pretrial Services Officer Paul Mamaril and with Assistant United States Attorney Shashi Kewalramani, who have no objections to Ms. Sander's requested travel. Under the circumstances I respectfully request that the court grant Ms. Sander's request. I declare under penalty of perjury that the foregoing is true and correct, and that this declaration is executed on January 16, 2008, at San Francisco, California.

/s/ RANDOLPH E. DAAR RANDOLPH E. DAAR

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