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Case No. CV-09-2236-SI

LAW OFFICE OF

ERICK L. GUZMAN

Cal. Bar No. 244391 

740 4th St.

Santa Rosa, California, 95404

T: 707.595.4474; F: 707.540.6298 

E: elg@guzmanlaw.org

Attorney for Defendant 

UNDER SEAL1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

QUINN WILRIDGE,

 Plaintiff,

 v.

JOHN MARSHALL, WARDEN,

 Defendant.

CASE NO. CV-09-2236-SI

EX PARTE APPLICATION TO ALLOW 

WITNESS ANTHONY WATSON TO

TESTIFY VIA VIDEO CONFERENCE

I

BACKGROUND

Mr. Wilridge anticipates calling Anthony Watson as a witness for the upcoming 

evidentiary hearing. Mr. Watson is currently housed at California Men’s Colony, San Luis 

Obispo. This Court has already signed a subpoena directing Mr. Watson to appear at the 

 

1 This pleading is being filed under seal because it reveals sensitive medical 

information regarding Mr. Watson. Undersigned counsel will provide a copy of this 

pleading to opposing counsel at the time of filing. 

Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 1 of 7
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2 Case No. CV-09-2236-SI

upcoming hearing. However, there is an issue with Mr. Watson traveling to San Francisco. 

Mr. Watson suffers from hepatitis C, genotype 1a stage 3-4. See Exhibit A. It is the 

understanding of undersigned counsel that this is a relatively rare form of hepatitis. Further, 

he is currently under a sensitive medication regime to treat the hepatitis C and the resultant 

liver problems. See id. For example, there is one medication that has to be administered on 

a very specific timetable.

Based on this situation, there is a concern that traveling to San Francisco would 

interfere with Mr. Watson’s medical treatment, and that the necessary medicine/treatment 

will not be available at whichever temporary facility they house Mr. Watson for the day 

prior to the hearing. 

I have raised this issue with Ms. Jill Thayer, Esq., counsel for the Government in this 

case. She has stated that she does not oppose this request to have Mr. Watson testify via 

video-conference. 

If a video-conference cannot be arranged, then Mr. Wilridge requests that Mr. 

Watson be allowed to testify telephonically. Undersigned counsel does not know Ms. 

Thayer’s position regarding Mr. Watson testifying telephonically. 

//

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Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 2 of 7
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3 Case No. CV-09-2236-SI

II

DECLARATION OF COUNSEL IN SUPPORT

I, Erick L. Guzman, Declare the following under penalty of perjury:

1. I am the attorney record in the above case. I was appointed pursuant to the 

Criminal Justice Act;

2. I am admitted to practice in California, and the Northern District of 

California; 

3. I have spoken with Mr. Watson and reviewed the medical documentation he 

has provided, and I do believe traveling from San Luis Obispo to San 

Francisco could pose a health risk to Mr. Watson given his sensitive medical 

situation, and the related medication schedule he is on. 

4. I do believe the Litigation Coordination department of California Men’s 

Colony, San Luis Obispo has the facilities to allow Mr. Watson to testify via 

video-conference. 

5. I do believe the Litigation Coordination department of California Men’s 

Colony, San Luis Obispo has the facilities to allow Mr. Watson to testify 

telephonically.

III

CONCLUSION

Mr. Wilridge respectfully requests this Court to order that Mr. Watson be allowed to 

testify via video-conference, and he not be brought to San Francisco for the upcoming 

evidentiary hearing. 

DATED: January 21, 2015 Respectfully submitted,

By 

Erick L. Guzman

Attorney for Wilridge

Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 3 of 7
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4 Case No. CV-09-2236-SI

UNDER SEAL

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

QUINN WILRIDGE,

Plaintiff,

v.

JOHN MARSHALL, WARDEN

Defendants.

No. CV 09-2236-SI

[PROPOSED] ORDER AUTHORIZING 

ANTHONY WATSON TO TESTIFY VIA

VIDEO-CONFERENCE, OR, IN THE 

ALTERANTIVE, ALLOWING MR. 

WATSON TO TESTIFY 

TELEPHONICALLY

For good cause shown, IT IS ORDERED that Anthony Watson be permitted to 

testify via video for the upcoming February 4, 2015 evidentiary hearing.

IT IS FURTHER ORDERED that, in the alternative, if video-conference is not 

available, that Mr. Watson be permitted to testify telephonically for the upcoming February 

4, 2015 evidentiary hearing. 

IT IS FUTHER ORDERED that Anthony Watson not be transported to San 

Francisco for the evidentiary hearing. Accordingly, the previously signed writ ad 

testificandum be vacated as to Anthony Watson only. 

IT IS SO ORDERED. 

Dated: ___________________________

HON. SUSAN ILLSTON

District Judge

1/23/15

Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 4 of 7
Exhibit A

Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 5 of 7
Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 6 of 7
Case 3:09-cv-02236-SI Document 104 Filed 01/23/15 Page 7 of 7