Free Declaration in Support - District Court of California - California

Case 3:07-cr-00605-MAG

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Filed 09/26/2007

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SCOTT N. SCHOOLS (SCBN 9990) United States Attorney BRIAN J. STRETCH (CABN 163973) Chief, Criminal Division WENDY THOMAS (NYBN 4315420) Special Assistant United States Attorney 450 Golden Gate Avenue, 11th Floor San Francisco, California 94102 Telephone: (415) 436-6809 Fax: (415) 436-7234 Email: [email protected] Attorneys for Plaintiff

9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 UNITED STATES OF AMERICA, 13 Plaintiff, 14 v. 15 RYAN SCHRADER, 16 Defendant. 17 18 I, Jalyn Wang, hereby declare as follows: 19 1. I am a Law Clerk in the United States Attorney's Office assigned to the prosecution of 20 this case. I have received the following information from officers employed by the United States 21 Park Police and from reports and other documents provided to me by the Park Police. 22 2. On August 3, 2007, at approximately 11:21 p.m., Officer Michael Cameron ("Officer 23 Cameron") of the United States Park Police was traveling west bound on Bunker Road through 24 the Baker Berry tunnel in the Presidio. Officer Cameron observed a Chevy Tahoe, California 25 license plate number 5ENJ816, proceed through a red light and enter the tunnel traveling east 26 bound. Officer Cameron turned his vehicle around and initiated a traffic stop on the Chevy 27 Tahoe for running a red light. 28
DECLARATION IN SUPPORT OF MOTION FOR SUMMONS Case No. CR 07-0605 MAG

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Case No. CR 07-0605 MAG DECLARATION OF JALYN WANG IN SUPPORT OF UNITED STATES' MOTION FOR SUMMONS

Case 3:07-cr-00605-MAG

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Filed 09/26/2007

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3. Officer Cameron approached the driver of the Chevy Tahoe, later identified as Ryan Schrader ("Defendant"). Officer Cameron immediately noticed that the Defendant was displaying objective signs of intoxication. Specifically, the Defendant had red watery eyes, slurred speech, slow motor skills, and an odor of alcoholic beverage. 4. Officer Cameron asked the Defendant to exit the vehicle, and he then conducted an investigative interview with the Defendant. During this interview, the Defendant stated that he had consumed one beer at approximately 5:30 or 6:00 p.m. The Defendant also stated that he had taken one pain killer approximately four hours prior to the instant conversation as well as a Xanax pill. When Officer Cameron asked the Defendant if he felt the effects of the medicine/drugs, the Defendant replied "yes." 5. Officer Cameron then conducted multiple field sobriety tests ("FST's") with the Defendant, including: (1) the "Walk and Turn"; (2) the "One Leg Stand"; (3) the "Rhomberg Stand"; (4) and the "Horizontal Gaze Nystagmus." The Defendant failed all of the FST's. 6. Officer Cameron read the Defendant the Chemical Test Admonition and the Defendant agreed to provide a urine sample. Officer Cameron and the Defendant went to 1217 Ralston in San Francisco so that the Defendant could provide a urine sample. At approximately 12:52 a.m., the Defendant voided his bladder. At approximately 1:50 a.m., the Defendant provided a urine sample for Officer Cameron. 7. Officer Cameron sent the vial of the Defendant's urine to the Department of Justice Bureau of Forensic Services, Santa Rosa Laboratory to be analyzed. On August 14, 2007, Senior Criminalist Samantha Evans analyzed the urine sample that the Santa Rosa Laboratory received from Officer Cameron, and determined that the sample of the Defendant's urine contained 0.25% (W/V) of alcohol. 8. Officer Cameron searched the Defendant's vehicle and recovered an aluminum 24 ounce Bud Light can from the center console, which was open and had approximately three quarters of the beer gone. // //
DECLARATION IN SUPPORT OF MOTION FOR SUMMONS Case No. CR 07-0605 MAG

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Case 3:07-cr-00605-MAG

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Filed 09/26/2007

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I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed September 25, 2007 at San Francisco, California.

DATED: _9/25/07____________

Respectfully submitted, SCOTT N. SCHOOLS United States Attorney /s/ JALYN WANG Law Clerk United States Attorney's Office

DECLARATION IN SUPPORT OF MOTION FOR SUMMONS Case No. CR 07-0605 MAG

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