Case 4:07-cv-04894-SBA
Document 51
Filed 06/24/2008
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JOSEPH P. RUSSONIELLO (SBN 44332) United States Attorney JOANNE M. SWANSON (SBN 88143) Chief, Civil Division ABRAHAM A. SIMMONS (SBN 146400) Assistant United States Attorney 450 Golden Gate Avenue, 9fi Floor San Francisco, California 94 102-3495 Telephone: 4 15-436-7264 Facsimile: 41 5-436-6748 Email: Abraham.simmons@usdo~ .gov Attorneys for Federal Defendant Seth McMullen UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION ROBERT CARL PATRICK KEANE, Individually; and CHIEKO STRANGE, Individually, Plaintiffs, v. SETH M. MCMLTLLEN, PAUL ACCORNERO and JOHN SILVA, Defendants.
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NO. C 07-4894 SBA DECLARATION OF ROBERT W. SCOTT, ][I, IN SUPPORT OF DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICATION OF ISSUES Fed.RCiv.P. 56
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I, Robert W. Scott, 11, declare as follows:
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I am an Executive Assistant Prosecutor assigned to the Grand Jury Unit of Ocean
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County Prosecutor's Ofice. I have reviewed and have personal knowledge of the facts in State of New Jersey v. Brian Keane, No. 06- 12-4361.
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In this case, Brian Keane, a New Jersey resident, was prosecuted for having
possession with the intent to distribute a controlled substance, in this case, marijuana.
Case 4:07-cv-04894-SBA
Document 51
Filed 06/24/2008
Page 2 of 2
3.
At no time did I contact officials from the U. S. Drug Enforcement Agency
("DEA") in connection with this case. In addition, to the best of my knowledge, no one other than an investigator in this office, John Murphy, had any contact with employees of the DEA regarding the Brian Keane case.
4.
To the best of my knowledge, this ofice never did ascertain the person from
whom Brian Keane received the marijuana.
I declare under penalty of perjury under the laws of the United States that the above is true and
accurate. Executed this day in
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,2008, in Toms River, New Jersey.