Free Motion to Travel - District Court of California - California

Case 5:07-cr-00610-JF

Document 13

Filed 01/02/2008

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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; 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 Portland, Oregon for a job interview, traveling to Portland on January 14, 2008 and returning to the Bay Area on January 15, 2008. This application is submitted after consultation with the supervising Pretrial Services Officer and the AUSA handling this matter, 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: January 2, 2008 Respectfully submitted, /S/______________________ Mark R. Vermeulen Attorney for Defendant BERNADETTE ESCUE -1-

Case 5:07-cr-00610-JF

Document 13

Filed 01/02/2008

Page 2 of 2

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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 Portland, Oregon for a job

interview on January 14-15, 2008. 3. I have spoken with Pretrial Services Officer Tim Elder, who is assigned to this case, and

with Joe Fazioli, the AUSA handling this case, and they both have informed me that they have no objection to this request. 4. I will fax a copy of this Application and the accompanying [Proposed] Order Permitting

Travel to Pretrial Services Officer Tim Elder 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 January 2, 2008 at San Francisco, CA.

/S/_____________________ Mark R. Vermeulen

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