IN THE UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF COLUMBIA CIRCUIT

IN RE: :

: Grand Jury_______

GRAND JURY SUBPOENA : No. xx-0395-02(JR)

________________________________:

MOTION TO QUASH SUBPOENA

Elise Haldane, counsel for xxxxxxxxxxx, respectfully moves this Court to quash a subpoena served upon her in this case. As grounds for this motion, the undersigned states:

1. During the late afternoon of January 12, 1998, Secret Service agent Brendan Pickett served a subpoena duces tecum upon counsel, directing her to appear before the Grand Jury on January 13, 1999, at 2:00 p.m. (Attachment A).

2. This case has been indicted, and is pending before the Honorable James Robertson.

3. This subpoena, served after a status hearing in this case on January 12, 1999, represents the latest chapter in a pattern of what appears to be harassment of Ms. xxxxxxx. (Attachment B).

4. The undersigned has not had sufficient time to prepare a detailed response to the subpoena due to the exceptionally late service.

WHEREFORE, for the foregoing reasons, and such other reasons as may become apparent at a hearing on this motion, counsel respectfully moves that the subpoena be quashed.

Respectfully submitted,

_________________________

Elise Haldane #242826

1900 L Street, NW #300

Washington, DC 20036

202-659-8700

POINTS AND AUTHORITIES

1. Local Rule 118(c).

2. United States v. Gertner, 65 F.3d 963 (1st Cir. 1995).

3. In Re Sealed Case, 146 F.3d 881 (D.C. Cir. 1998).

4. Swidler & Berlin v. United States, 118 S.Ct. 2081 (1998).

________________________

Elise Haldane

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Motion, Points and Authorities In Support thereof and propose order has been served by hand upon Ann Carroll, Assistant United States Attorney, by delivering a copy thereof to her at the United Staes District Court, 333 Constitution Avenue, N.W. Washington, D.C. 20001, this13th day of January, 1999.

Elise Haldane

IN THE UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF COLUMBIA CIRCUIT

IN RE: :

: Grand Jury_______

GRAND JURY SUBPOENA : No. xx-0395-02 (JR)

________________________________:

ORDER

Upon consideration of the Motion to Quash Subpoena and Incorporated Points and Authorities in Support Thereof filed herein on _______ January 1999, it is

HEREBY ORDERED that the subpoena shall be and hereby is quashed.

AND, IT IS FURTHER ORDERED,

That the Office of the United States Attorney shall not serve any subpoena or cause the arrest of Olanike xxxxxxx, or her counsel, without prior authorization of this court.

______________________________

Honorable Norma Holloway Johnson

United States District Judge

Copies To:

Ann Carroll

Assistant United States Attorney

Office of the United States Attorney

555 Fourth Street, N.W.

Washington, D.C. 20001

Elise Haldane #242826

1900 L Street, NW #300

Washington, DC 20036

202-659-8700