Opinion
RANDY SUE POLLOCK, Attorney at Law, Oakland, CA, Attorney for Defendant.
DECLARATION OF COUNSEL IN SUPPORT OF RETURN OF DEFENDANT [PROPOSED] ORDER TO RETURN PASSPORT TO DEFENDANT
I, Randy Sue Pollock, declare and state as follows:
1. That I am an attorney duly licensed to practice law before the Courts of the State of California and the United States District Court for the Northern District of California;.
2. That I am the court-appointed counsel for defendant Min Young Bang, in CR. No. 05-00395-CRB;
3. This declaration is made in support of an ex parte application of defendant for the return of his Korean;
4. On July 7, 2006, defendant Bang was sentenced to three years supervised release;
5. On October 2, 2006, Mr. Bang appeared before the Immigration Court and was granted a voluntary departure. He is a citizen of Korea;
6. Mr. Bang is scheduled to leave the United States in the first week of March;
7. In order to finalize his travel plans Mr. Bang needs his passport that was surrendered to this Court on December 19, 2005;
8. AUSA Peter Axelrod has no objection to returning the passport to Mr. Bang so that he can go back to Korea.
I declare under penalty that the above is true and correct to the best of my knowledge. Executed this 25th day of February, 2007 in Oakland, CA.
GOOD CAUSE SHOWN, based on the fact that defendant Min Young Bang has been sentenced and is on supervised release and plans to return to Korea in March 2007, IT IS HEREBY ORDERED that his passport that was surrendered to the U.S. District Court Clerk on December 19, 2005, shall be returned to him.