State of Arizona )
) ss.
County of Maricopa )
James C. Braden, being tirst duly sworn upon his oath. hereby deposes and says:
l. That l am the attorney who represented John Derrick Martin at trial in United States v.
John Derrick Martin in the District Court for the District of Arizona in CR—O2—()l 55—PHX—JAT.
2. That l personally met with John Derrick Martin on multiple occasions to discuss his case
whicli involved the conspiracy topossess and attempted possession of Eve kilograms or
more of cocaine. _ A
3. That. as to the issue of severance, l was aware that the court denied John Derrick Martin ’s
motion to sever which was filed by previous attorney.
4. That prior to trial and during the course oftrial, l contacted Michael S. Ryan. counsel for
co—defendant Steve Cordell Dobson, to determine whether Steve Cordell Dobson would testify on
behalf of John Derrick Martin. That, based on my conversations with Michael Ryan, Steve
Cordell Dobson. would not testify on John Derrick Ma1tin’s behalf ln fact. Steve Cordell Dobson
did not testify at trial.
5. That had Steve Cordell Dobson agreed to provide testimony on John Derrick Martin’s
» behalf l would have re—urged the motion for severance from the co—defendants.
6. That. as to the claim that John Derrick Martin allegedly had prior contact with Special
Agent Benny Goodman thereby atiecting the pretrial identiticatien, at no time during the period of
time l represented him, did John Derrick Martin ever indicate that he had prior contact with Agent
Goodman. A
7. That, as to the clainttlzet I should have traveled to Tennessee to view the scene, the
government provided lull discovery which included a surveillance videotape taken at the time ofthe
offense and photographs of all relevant locations including ariel photographs which l thoroughly
reviewed.
8. That, as to the governnient’s witnesses, which were all law enforcement ofticers or agents
acting on behalf of law enforcement. l was provided with written reports detailing the witnesses’ role
in the investigation which l thoroughly reviewed.
9. That, during the course cf my representation. l asked John Derrick Martin for names of
any witness who may be able to establish an alibi defense. John Derrick Martin originally told me
‘ l
nt 349-2 Filed 04/11/2007 Page 1 of 2
Case 2:02-cr-00155-JAT Docume
that he did not have anyone who could testify.
10. That. approximately one week before trial, John Derrick Martin called me and said he
had witnesses who would contact me regarding his whereabouts at the time of the offense. At that
tinie, John Derrick Martin would not provide me with any names.
1 1. That, at a later date, I received a call from ag woman who did not identify herself or
provide any contact infomation. We discussed whether she could provide an alibi for John Derrick
Martin. She requested that I provide her the date ofthe offense. At that time, she did not supply me
with any information regarding a possible alibi tor John Derrick Martin. She indicated that she
would travel to Phoenix and would contact me at that time. I never heard from this person again.
E2. Further the aftiant sayeth naught. Z
{ z - 4 _
AMES C. B '• · E ‘
SUBSCRIBED and SWORN to bef · me this !0%
‘ , $,0 Official Seal ’
HT TM, Laura M. Krajewski NOMYY Public
g Notary Public · State of Arizona
* Maricopa County
° *°*“ My Comm. Expires April 23, 2008
iUrE¤Thii§§itYr{"E$< "i i'`i` "W
l
. f 2 I
- FI d O4/11/2007 PGQG 2 O
Case 2:02-cr-00155-JAT Document 349 2 I 9 E
Case 2:02-cr-00155-JAT
Document 349-2
Filed 04/11/2007
Page 1 of 2
Case 2:02-cr-00155-JAT
Document 349-2
Filed 04/11/2007
Page 2 of 2