Free Motion to Modify Conditions of Release - District Court of Arizona - Arizona

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FEOLA & TRAICA
A PROFESSIONAL CORPORATION ATTORNEYS and COUNSELLORS at LAW

2800 N. Central Avenue, Suite 1400 Phoenix, Arizona 85004-1045 [email protected] _____________

(602) 277-7473 Fax (602) 274-2129

David L. Lockhart State Bar No. 018475 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. MICHAEL CRAIG ANDERSON, Defendant. Defendant Michael Craig Anderson, by and through undersigned counsel, respectfully moves this Honorable Court for permission to travel with his wife, Gina, the co-defendant in this matter, to San Diego, California to attend his son, Justin's, football game, this Friday, November 19, 2005. Defendant and his wife plan on returning to the State of Arizona no later than Monday, November 21, 2005. Co-Defendant Gina Anderson joins in this motion. Undersigned has contacted Assistant United States Attorney John Boyle regarding Defendant's requests and avows that Mr. Boyle has no objection. In addition, undersigned has contacted, Ruben Salgado, the Defendants' assigned Pre-trial officer in Yuma, Arizona, and Mr. Salgado has no objection to the requests made herein. For the reasons stated above, undersigned counsel, respectfully requests this that Honorable Court grant this Motion and enter an Order modifying the prior release Order to allow both No. CR 04-01281-001-PHX-DGC MOTION TO TRAVEL

Case 2:04-cr-01281-DGC

Document 62

Filed 11/16/2005

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Defendants to travel outside the State of Arizona for the purposes of attending their son's football game in San Diego, California. Excludable delay under 18 U.S.C. §3161(h)(1)(F) and 8(A) will not occur as a result of this Motion or an Order based thereon. RESPECTFULLY SUBMITTED this 16th day of November, 2005. FEOLA & TRAICA, P.C.

By

FEOLA & TRAICA, P.C.

10
2800 N. Central Ave., Suite 1400 Phoenix, Arizona 85004-1045

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s/David L. Lockhart David L. Lockhart, Esq. 2800 N. Central Avenue Suite 1400 Phoenix, AZ 85004 Attorneys for Defendant

CERTIFICATE OF SERVICE I certify that on November 16, 2005, I electronically transmitted this document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Clerk of the Court The Honorable David G. Campbell United States District Court Judge 401 W. Washington Phoenix, Arizona 85003 John Z. Boyle, Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408 Patricia A. Gitre, Esq. Patricia A. Gitre, P.L.C. 331 N. First Avenue, Suite 150 Phoenix, Arizona 85003 Counsel for co-Defendant Gina D. Anderson

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