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UNITED STATES DISTRICT COURT

FOR THE

DISTRICT OF NEW HAMPSHIRE

* * * * * * * * * * * * * * * * * * * * * * * * *

* ** UNITED STATES OF AMERICA*

* *

* v. * 07-CR-189

* *

* CIRINO GONZALEZ *

* *

* * * * * * * * * * * * * * * * * * * * * * * * *

MOTION FOR ADDITIONAL SUBPOENAS AND AUTHORIZATION FOR

WITNESSES TO TRAVEL FROM JURISDICTIONS OTHER THAN

THE STATE OF NEW HAMPSHIRE

NOW COMES the defendant, Cirino Gonzalez, by counsel, David H. Bownes, Esq. and

respectfully requests that this Court Authorize the Issuance of Additional Subpoenas beyond the

five (5) as established by Rule [LCrR 17.1(a),] and in addition Authorize Travel for Witnesses

from Jurisdictions Outside the District of New Hampshire.

As grounds for this request it is stated:

1. The defendant this day has submitted a Preliminary Witness List of more than thirty-

seven (30) witnesses including potential witnesses from the District of New Hampshire, Texas,

Vermont, California and other States.

2. Depending upon the Governments evidence with respect to this matter, there is a

potential that all or nearly all of the witnesses listed in the Defendants Preliminary Witness List

will be necessary in order to effectively address the factual issues that arise during the course of

the trial.

3. It would be counsels intent to prepare subpoenas for each of the out of state witnesses

and forward them to the various U.S. Marshalls Offices having jurisdiction together with a

certified copy of this order.

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4. Because some of the witnesses are out of State and traveling from places such as

Texas, California and other states, it may be more appropriate for an order explicitly authorizing

travel expenses for those witnesses.

5. Before the defendant actually sends out a request to the U.S. Marshall with respect to

witnesses outside the District of N.H., the defendant will inform the Court, on an ex-parte basis,

of his intent to do so and the reasons that the witness is necessary for purposes of a resolution of

the factual issues in this case.

6. Due to the nature of this request, concurrence from the U.S. Attorneys Office has not

been sought.

WHEREFORE the defendant requests that this Court grant the following relief:

A. Authorize the issuance of subpoenas for (but not necessary limited to) thirty (30)

witnesses in this matter;

B. Authorize the travel for those witnesses subpoenaed from jurisdictions other than the

District of New Hampshire;

C. For such further relief as may be just.

Respectfully Submitted,

Cirino Gonzalez,

By His Attorneys,

Dated: 1/22/08 /S/ David H. Bownes, Esq.

David H. Bownes, Esq.

NH Bar No.: 277486 Union Avenue

Laconia, NH 03246

(603) 524-4330

office@dhblaw.net

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CERTIFICATION

I hereby certify that on this 22nd day of January, 2007, that a copy of the foregoing

Motion for Additional Subpoenas and Authorization for Witnesses to Travel From Jurisdictions

other than the State of New Hampshire has been forwarded to Arnold Huftalen, Esq., UnitedStates Attorneys Office, Paul Garrity, Esq,, and to Stanley Norkunas, Esq. via ECF and to

Daniel Riley at the Strafford House of Corrections via U.S. First Class Mail.

/S/ David H. Bownes, Esq.

David H. Bownes, Esq.