Free Motion to Travel - District Court of California - California

Case 5:07-cr-00610-JF

Document 24

Filed 04/15/2008

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Mark R. Vermeulen [CSBN 115381] Law Office of Mark R. Vermeulen 755 Florida Street #4 San Francisco, CA 94110.2044 Phone: 415.824.7533 Fax: 415.824.4833 Attorney for Defendant BERNADETTE ESCUE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION UNITED STATES OF AMERICA, Plaintiff, v. BERNADETTE ESCUE, Defendant. ) ) ) ) ) ) ) ) ) No. CR 07-00610 JF EX PARTE APPLICATION FOR ORDER PERMITTING TRAVEL IN CONNECTION WITH DEFENDANT'S NEW EMPLOYMENT, SUBMITTED WITH THE APPROVAL OF THE AUSA AND PRETRIAL SERVICES; DECLARATION OF COUNSEL

Defendant Bernadette Escue, through counsel, applies for permission to travel to and from Seattle, Washington from April 21-25, 2008, in connection with an orientation program offered to new hires for the company with which she recently began working. This application is submitted after consultation with the AUSA and the supervising Pretrial Services Officer, both of whom have informed counsel that they have no objection to this request. This Application is based on the attached Declaration Of Counsel. A proposed order accompanies this application.

Dated: April 15, 2008

Respectfully submitted,

/S/______________________ Mark R. Vermeulen Attorney for Defendant BERNADETTE ESCUE -1-

Case 5:07-cr-00610-JF

Document 24

Filed 04/15/2008

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DECLARATION OF COUNSEL I, Mark R. Vermeulen, declare: 1. I am an attorney duly admitted to practice before this Court and I represent Defendant

Bernadette Escue in this action. 2. I request that Ms. Escue be permitted to travel to and from Seattle, Washington from

April 21-25, 2008. She recently was hired by a new employer and she needs to attend an orientation program offered to new hires by her new employer during those dates. 3. I have spoken with Pretrial Services Officer Tim Elder, who is assigned to this case, and

with Susan Knight, who is standing in for AUSA Joe Fazioli (the AUSA handling this case), as Mr. Fazioli is currently not available. Both Mr. Elder and Ms. Knight have informed me that they have no objection to this request. 4. I will email a copy of this Application and the accompanying [Proposed] Order

Permitting Travel to Pretrial Services Officer Tim Elder and to AUSA Susan Knight on the same date I file this via ECF, and a copy of each will be provided to AUSA Joe Fazioli automatically via ECF filing. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 15, 2008 at San Francisco, CA.

/S/_____________________ Mark R. Vermeulen

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