(E)  Assistance from Foreign Consulate.  The Vienna Convention on Consular Relations requires federal and state law enforcement to notify every foreign national who is arrested within the United States of his or her right to consult with consular officials from their home country.[236]  The consular officials will, in fact, often be of great assistance to the foreign national, and to defense counsel, in such matters as arranging foreign investigation, letters rogatory, assistance from foreign courts, and the like, so this source of assistance should not be overlooked.

[236] Vienna Convention on Consular Relations, Apr. 24, 1963, 21 U.S.T. 77, T.I.A.S. No. 6820, Art. 36(1)(b).

Tenth Circuit

REMOVAL PROCEEDINGS - VIENNA CONVENTION
De La Cruz v. Maurer, 483 F.3d 1013 (10th Cir. April 3, 2007) (rejecting argument that the INS's failure to apprise him that he was entitled to communicate with Mexican consular or diplomatic officers under the Vienna Convention and immigration regulations violates Article 36(1)(b) of the Vienna Convention on Consular Relations and 8 C.F.R. 236.1(e), on grounds the argument was waived because he failed to assert the issue before the IJ, and, in any event, Torres could not show that the violation resulted in any prejudice).

Other

BIBLIOGRAPHY - INVESTIGATION - FOREIGN INVESTIGATION
Ross Garber, Gathering Defense Evidence Abroad, 33 The Champion, No. 8, p. 22 (Sept.-Oct. 2009).

CRIMINAL DEFENSE - INVESTIGATION
L. Friedman Ramirez, Federal Law Issues in Obtaining Evidence Abroad, in L. FRIEDMAN RAMIREZ, ED., CULTURAL ISSUES IN CRIMINAL DEFENSE 273 (2d ed. 2007).

BIBLIOGRAPHY
Extradition and Foreign Evidence Blog http://obtainingforeignevidence.blogspot.com/