Case5:08-cr-00938-JW Document209 Filed04/06/11 Page1 of 3

1 J. TONY SERRA #32639

SHARI L. WHITE #180438
2 506 Broadway
San Francisco CA 94133
3 Telephone: 415/986-5591
Facsimile: 415/421-1331
4
Attorneys for Defendant
5 JAMIE HARMON

8 UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
9 SAN JOSE DIVISION

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11 UNITED STATES OF AMERICA, No. CR 08-938 JW

12 Plaintiff, EX PARTE MOTION TO PERMIT

TRAVEL AND [PROPOSED] ORDER
13 v.

14 JAMIE HARMON,

15 Defendant.
/
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17 Defendant HARMON was indicted on six felony charges:

18 conspiracy to launder monetary instruments (Count Two) and

19 laundering of monetary instruments (Counts Three through Seven)

20 in violation of 18 U.S.C. §§ 1956(h) and 1956(A)(i)(b)(i),

21 respectively. On January 7, 2009, she appeared and was released

22 on a $100,000 signature bond. A trial by jury of the matter was

23 commenced on July 6, 2010.

24 On July 20, 2010, the jury was unable to reach a unanimous

25 verdict on the conspiracy count, Count Two, but convicted

26 Defendant on the remaining substantive counts. The court

27 declared a mistrial as to Count Two. She has attended all

LAW OFFICES
506 BROADW AY 28 required hearings and appearances since that time.
SAN FRANCISCO
(415) 986-5591
Fax: (415) 421-1331

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1 Among the conditions of her signature bond release is the

2 restriction that she not travel outside the Northern District of

3 California. Ms. Harmon has complied fully with the order of the

4 Court and attended each required hearing as ordered.

5 Ms. Harmon requests permission to travel within the United

6 States, specifically to the State of Colorado. Ms. Harmon

7 intends to leave the State of California on April 12, 2011, and

8 return on April 18, 2011.

9 Jaime Carranza, with pretrial services, has been consulted

10 regarding this proposed travel and does not object. All travel

11 itinerary will be provided directly to Mr. Carranza.

12 Dated: April 6, 2011 Respectfully submitted,

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14 /s/ J. TONY SERRA

J. TONY SERRA
15 SHARI L. WHITE
Attorneys for Defendant
16 JAMIE HARMON

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LAW OFFICES
506 BROADW AY 28
SAN FRANCISCO
(415) 986-5591
Fax: (415) 421-1331

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1 DECLARATION OF COUNSEL

2 I, J. Tony Serra, do hereby declare:

3 1. That I am an attorney licensed to practice in the State of

4 California and am admitted to practice before this Court.

5 2. That I represent the defendant in the above entitled

6 action:

7 3. Jamie Harmon would like to travel to the State of Colorado.

8 4. Ms. Harmon anticipates a departure on April 12, 2011, and a

9 return on April 18, 2011.

10 5. Jaime Carranza with pretrial services has been consulted

11 regarding the proposed travel and does not object.

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13 I swear under penalty of perjury that the above is true and

14 correct under the laws of these United States and the State of

15 California.

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/s/ J. TONY SERRA
17 J. TONY SERRA

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LAW OFFICES
506 BROADW AY 28
SAN FRANCISCO
(415) 986-5591
Fax: (415) 421-1331