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4. On information and belief, Ms. Brown was unable to pay
the surety bond imposed by Magistrate Judge Heany and is currently
in custody at the Oceana Detention Center pending her trial.
5. Defendant therefore requests this honorable court to issue
a Writ of Habeas Corpus ad Testificandum directing the U.S.
Marshals to bring Ms. Brown from the Oceana Detention Center,
or any other federal, state or local detention facility Ms.
Brown may be moved to prior to defendant’s trial, to
the cellblock behind Courtroom 15 on the first day set for
defendant’s trial, so that Ms. Brown is available to
Mr. Jones as a witness.
Respectfully submitted,
Susan
Chase____________
Ms. Susan Chase, Esq.
Attorney for Defendant
(123) 878-1234
NOTICE OF SERVICE
I hereby certify that this motion was personally served
upon the attorney for the government, AUSA Rhonda Johnson,
this 30th day of September, 2003.
Susan
Chase____________
Susan Chase, Esq.
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