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JOHN J. JORDAN, ESQ. (State Bar No. 175678)

601 Montgomery Street, Suite 850

San Francisco, CA 94111

Tel: (415) 391-4814

Fax: (415) 391-4309

Email:jjordanesq@aol.com

Counsel for Defendant 

HARRISON LAMON

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

Plaintiff,

vs.

HARRISON LAMON, 

Defendant.

_____________________________________

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No. CR 17-0006-VC

DEFENDANT’S UNOPPOSED MOTION

TO ORDER DISCLOSURE OF NEW

BRIDGE RECORDS

HON. VINCE CHHABRIA

INTRODUCTION 

The defendant, HARRISON LAMON, through counsel of record, John J. Jordan, hereby

moves this Court for an Order directing the New Bridge Foundation's custodian of records to

release a copy of the records of the defendant’s treatment at the New Bridge Foundation to

defense counsel, for the purpose of providing the records to court-appointed psychologist Dr.

John Shields, for his use in preparing a sentencing report for the Court. 

1. On November 29, 2016, the defendant was charged by complaint with receipt of child

pornography, in violation of 18 U.S.C. § 2252(a)(2); and possession of child pornography, in

violation of 18 U.S.C. § 2252(a)(4)(B). CR 1. 

2. On December 23, 2016, the defendant was released on bond, with a condition that he

enter treatment at the New Bridge Foundation, 2323 Hearst Ave, Berkeley, CA 94709.

Motion to Disclose Newbridge Records 1

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3. On January 6, 2017, a three count Superseding Information was filed in the Northern

District of California, charging Lamon with receipt of child pornography, in violation of 18

U.S.C. § 2252(a)(2) (count one); distribution of child pornography, in violation of 18 U.S.C. §

2252(a)(2) (count two); and possession of child pornography, in violation of 18 U.S.C. §

2252(a)(4)(B) (count three). CR 1. 

4. On April 24, 2017, Lamon pled guilty to all three counts of the Superseding

Information, pursuant to a written plea agreement with the government. CR 24, 25. Sentencing

is now set for the defendant on September 16, 2018. CR 50. The defendant has successfully

completed a six month program at New Bridge and is currently in transitional housing.

5. Subsequent to Lamon’s plea, the Court authorized the appointment of defense expert

Dr. John Shields, a forensic psychologist, to prepare a report for use at sentencing. 

6. Dr. Shields has requested access to Lamon’s records while at New Bridge, to assess

his progress under therapy and other treatment for the past year and a half. 

7. Counsel for Lamon requested production of the records pursuant to a signed medical

release by the defendant, but New Bridge has informed counsel that Lamon’s status as a United

States pre-trial release patient requires approval by the Court for release of the records.

8. On June 26, 2018, counsel for Lamon spoke with U.S. Pretrial Services Officer K.J.

Gibson, who confirmed that the Court policy for someone receiving drug and/or psychiatric

treatment as a condition of pre-trial release is it that a court order would be needed for the release

of the records. Officer Gibson informed counsel that his office takes no position on counsel’s

request for this order.

9. On June 26, 2018, counsel for Lamon spoke with AUSA Karen Kreuzkamp, who

informed counsel that she believed it was necessary for Dr. Shields to be able to review the

defendant’s activities for the past 18 months and so joins in this motion. 

10. Disclosure here would thus be appropriate in the interest of justice, particularly as the

records sought pertain only to the defendant, and he has already provided a medical release form

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to New Bridge.

11. A proposed order is attached to this motion.

Accordingly, defendant Lamon moves for an Order directing the New Bridge

Foundation's custodian of records to release a copy of the records of the defendant’s treatment at

the New Bridge Foundation to defense counsel of record John J. Jordan, for the purpose of

providing the records to court-appointed psychologist Dr. John Shields, for his use in preparing a

sentencing report for the Court. 

DATED: June 27, 2018 Respectfully submitted,

/s/ John J. Jordan

JOHN J. JORDAN

Attorney for Defendant

HARRISON LAMON

Motion to Disclose Newbridge Records 3

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