Free Declaration in Support - District Court of California - California

Case 3:07-cr-00594-PJH

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EDWIN K. PRATHER (State Bar No. 190536) 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. Case No. CR-07-0594 PJH DECLARATION OF EDWIN K. PRATHER IN SUPPORT OF DEFENDANT JEFFREY HARRISON'S MOTION TO MODIFY CONDITIONS OF PRETRIAL RELEASE Date: Time: Judge: January 17, 2008 9:30 a.m. Hon. James Larson

I, EDWIN PRATHER, declare the following: 1. I am an attorney at law licensed to practice in the State of California and an

attorney of record for the defendant Jeffrey Harrison in the above-captioned case. I make this declaration in support of Mr. Harrison's Motion to Modify Conditions of Pretrial Release. I have personal knowledge of the following facts and, if called upon to do so, I could and would competently testify thereto. 2. of the United States. 3. Mr. Harrison intends to travel to Manila in connection with the business he
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Per the terms of Mr. Harrison's release, he is not allowed to travel outside

started, Global Mobile Technologies (GMT), which is developing new methods of

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delivering internet content to cellular phones. Prior to his arrest in this matter, Mr. Harrison served as GMT's CEO and legal counsel, and developed the company's business and technology models. Investors have contributed more than $7,000,000 to GMT. 5. GMT has been without executive leadership since Mr. Harrison's arrest in

this matter. Three executive team candidates will be in the Philippines to meet Mr. Harrison, be briefed on the company's technologies and business models, and be presented to GMT's proposed customers and business partners. These entities include Proctor & Gamble, JobsDB, Philippine Long Distance Telephone Company, and Smart Cellular. 6. GMT and Mr. Harrison have previously attempted, and failed, to conduct

these detailed presentations to executive candidates and proposed customers without Mr. Harrison's personal presence. 7. Attached as "Exhibit A" is a letter from Michael Dobbs-Higginson, as well

as a biography of Mr. Dobbs-Higginson. He is the former chairperson of Merrill Lynch Asia Pacific, and current chairperson of GMT's board of directors. Mr. Dobbs-Higginson is also in charge of funding GMT, and his letter details the necessity of Mr. Harrison's trip. Mr. DobbsHigginson believes that, absent Mr. Harrison's personal presence at these meetings, GMT will dissolve and its investors will lose their money. 8. technologies. Attached as "Exhibit B" are two samples of press articles about GMT's

Dated: January 10, 2008

Respectfully submitted, /s/: Edwin K. Prather EDWIN K. PRATHER Clarence & Dyer LLP Attorneys for Jeffrey Harrison

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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 January 11, 2008, I served a copy, with all exhibits, of the following documents: · DECLARATION OF EDWIN K. PRATHER IN SUPPORT OF DEFENDANT JEFFREY HARRISON'S MOTION TO MODIFY CONDITIONS OF PRETRIAL RELEASE

___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]
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

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