Free Proposed Order - District Court of California - California

Case 3:07-cr-00594-PJH

Document 60

Filed 03/12/2008

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

NANCI L. CLARENCE (State Bar No. 122286) CRAIG H. BESSENGER (State Bar No. 245787) CLARENCE & DYER LLP 899 Ellis Street San Francisco, California 94109 Telephone: 415.749.1800 Facsimile: 415.749.1694 Email: [email protected] [email protected] Attorneys for Defendant Jeffrey Harrison

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, Plaintiff, v. JEFFREY HARRISON, Defendant. On March 10, 2008, defense counsel filed a stipulation and proposed order with the Court regarding Mr. Harrison's request to travel to Los Angeles, California to attend his son's wedding. Later that day, defense counsel received a copy of Rich Sarlatte's memorandum to the Court regarding Mr. Harrison's alleged violation of the terms of his pretrial release. Defense counsel subsequently spoke with Mr. Sarlatte and AUSA Denise Barton separately and informed them that the stipulation and proposed order for Mr. Harrison's travel request would be withdrawn pending the resolution of Mr. Sarlatte's concerns at a hearing. On March 11, 2008, prior to the stipulation and proposed order being withdrawn, the Court signed the proposed order authorizing Mr. Harrison's travel. In light of the timing of these events, the Government and defense counsel now agree that Mr. Harrison will not travel to Los Angeles as planned, pending the outcome of the hearing requested by Mr. Sarlatte.
Page 1 Stipulation and [Proposed] Order Regarding Defendant Jeffrey Harrison's Travel Request [CR No.: 07-0594 PJH]

CR No.: 07-0594 PJH STIPULATION AND [PROPOSED] ORDER REGARDING DEFENDANT JEFFREY HARRISON'S TRAVEL REQUEST

Case 3:07-cr-00594-PJH

Document 60

Filed 03/12/2008

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Page 2 Stipulation and [Proposed] Order Regarding Defendant Jeffrey Harrison's Travel Request [CR No.: 07-0594 PJH]

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: March

, 2008

_______________________________________ Honorable James Larson United States District Chief Magistrate Judge

Approved as to form: /s/: Craig H. Bessenger CRAIG H. BESSENGER Clarence & Dyer LLP Attorneys for Defendant Jeffrey Harrison

_/s/: Denise Marie Barton__________ DENISE MARIE BARTON Assistant United States Attorney

Case 3:07-cr-00594-PJH

Document 60

Filed 03/12/2008

Page 3 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Proof of Service I, Abbie Chin, declare as follows: I am over eighteen years of age and not a party to the within action; my business address is 899 Ellis Street, San Francisco, California 94109; I am employed in the County of San Francisco. On March 12, 2008, I served a copy, with all exhibits, of the following documents: · STIPULATION AND [PROPOSED] REGARDING DEFENDANT JEFFREY HARRISON'S TRAVEL REQUEST ___X___ (BY ELECTRONIC SERVICE) I caused an electronic delivery subject to 28 U.S.C ¶1746, Local Rules or General Orders of this Court regarding Electronic Case Filing. All pleadings and papers must be electronically served in accordance with those Rules or General Orders with email address(es) as noted below:

Denise Marie Barton United States Attorney's Office 450 Golden Gate Avenue, 11th Floor Box 36055 San Francisco, CA 94102 415-436-7359 Fax: 415-436-7234 Email: [email protected]
___X___ (BY FAX) By transmitting by facsimile machine to the number addressed as below; the facsimile machine I used complied with California Rules of Court, rule 2003 and no error was reported by the machine. Pursuant to California Rules of Court, rule 2006(d), I caused the machine to print a transmission record of the transmission. Rich Sarlatte United States Pretrial Services Fax: (415) 436-7517 I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct and that this declaration was executed on the above stated date.

/s/: Abbie Chin Abbie Chin

Page 3 Stipulation and [Proposed] Order Regarding Defendant Jeffrey Harrison's Travel Request [CR No.: 07-0594 PJH]