UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

UNITED STATES OF AMERICA

v.	CRIMINAL DOCKET H-00-0000

CLIENT

FILED UNDER SEAL

EX PARTE MOTION FOR APPROVAL TO EMPLOY

PRIVATE INVESTIGATOR

Defendant, CLIENT asks for approval to employ INVESTIGATOR as a private investigator,
and respectfully moves this Court to enter an order authorizing counsel to incur expenses for

investigative assistance not to exceed $1,600.00. In support of this motion, the defendant states:

I.

Defendant is charged in an eleven count fraud indictment. Defendant is charged with mail fraud, fraud in connection with identification documents, fraud in connection with access devices and aggravated identity theft. Counsel has identified several potential material witnesses in this case. Counsel needs investigative assistance to locate and interview these witnesses. Counsel needs further assistance in conducting thorough background checks on these witnesses. INVESTIGATOR's tasks will include investigation of issues relevant to both the guilt/innocence and penalty phases of the case. They will also investigate the credibility of prosecution witnesses who will testify against CLIENT.

III.

Pursuant to 18 U.S.C. 3006(A), defendant requests that this Honorable Court authorize counsel to incur reasonable investigative expenses not to exceed $1,600.00.

WHEREFORE, PREMISES CONSIDERED, defendant prays that this

court grant this ex parte application for approval to employ a private investigator.

Respectfully submitted,

____________________

DEFENSE COUNSEL

Federal Identification No. 0000

0000 Shark Infested Lane

Suite 000

Houston, Texas 77000

(713) 000-0000

(713) 000-0000 (Fax)

CERTIFICATE OF SERVICE

This document was filed ex parte and under seal. A copy was not provided to the government.

____________________

DEFENSE COUNSEL

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

UNITED STATES OF AMERICA

v.	Cr. No. H-00-0000

CLIENT

FILED UNDER SEAL

ORDER ON

EX PARTE MOTION FOR APPROVAL TO EMPLOY MITIGATION SPECIALIST AND PRIVATE INVESTIGATOR

CLIENT's ex parte motion for approval to employ private investigator is:

GRANTED/DENIED.

CLIENT is authorized to retain the investigative services of Mr. INVESTIGATOR of Investigators Are Us and expend a total of $1600.00 to begin a factual investigation..

Signed in Houston, Texas on _______________ __________, 2009

_________________________

United States District Judge