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DECLARATION OF H. DEAN STEWARD

I H. Dean Steward, declare,

1. Along with attorney Jerome Haig, I am one of two retained counsel for

defendant Paul Tanaka.

2. On August 7, 2015, Assistant United States Attorney Brandon Fox advised me

that the government would not be granting immunity to Leroy Baca for any

prospective testimony in this matter.

2. On August 10, 2015, I spoke with attorney Brian Hershman. Mr. Hershman

represents former L.A. County Sheriff Leroy Baca. I told Mr. Hershman that it is

highly likely that we will call his client at trial as a witness. I have already served

Mr. Baca with a trial subpoena. I asked Mr. Hershman if his client would assert his

rights under the 5th Amendment. Mr. Hershman told me that no decision has been

made to date, but 5th Amendment assertion by Mr. Baca is a strong possibility.

I declare under penalty of perjury that the foregoing is true and correct.

Dated: August 13, 2015 s/. H. Dean Steward

Case 2:15-cr-00255-PA Document 67-1 Filed 08/14/15 Page 1 of 1 Page ID #:467