Free Notice (Other) - District Court of California - California

Case 3:07-cr-00594-PJH

Document 43

Filed 01/11/2008

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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. Date: Time: Judge: January 17, 2008 9:30 a.m. Hon. James Larson Case No. CR-07-0594 PJH DECLARATION OF EDWIN K. PRATHER IN SUPPORT OF DEFENDANT'S APPLICATION FOR ORDER SHORTENING TIME FOR HEARING ON MOTION TO MODIFY CONDITIONS OF PRETRIAL RELEASE

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 Application for Order Shortening Time for Hearing on 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. On January 10, 2008, I spoke with Assistant United States Attorney Denise

Barton regarding this matter. Ms. Barton agreed the Government would not oppose this Application for Order Shortening Time, and further agreed that she would be prepared to
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Case 3:07-cr-00594-PJH

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respond to the underlying motion on January 17, 2008. 3. On January 10, 2008, I spoke with Rich Sarlatte, Mr. Harrison's Pretrial

Services Officer, and alerted Mr. Sarlatte to the underlying motion and to our request to have the motion heard on January 17, 2008. Mr. Sarlatte agreed he was available for such a hearing on that date. 4. Defendant's motion must be heard on shortened time because the requested

modification of pretrial release conditions is related to meetings scheduled for the week of January 20, 2008 in the Philippines. 5. The meetings are a final effort to avoid the collapse of Global Mobile

Technologies (GMT) by transitioning to a new executive leadership team and introducing that team to prospective customers and business partners of GMT. To date, GMT has been the recipient of over $7,000,000 of investment capital.

Dated: January 10, 2008

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

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Case 3:07-cr-00594-PJH

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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'S APPLICATION FOR ORDER SHORTENING TIME FOR HEARING ON 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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