Free Response to Motion - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams, Suite 201 3 Phoenix, Arizona 85007 Telephone: (602) 382-2753 4 DONNA LEE ELM, #012127 5 Asst. Federal Public Defender Attorney for Defendant 6 [email protected] 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. James D. Perino, Defendant. James D. Perino, through undersigned counsel, respectfully responds to the Government's Motion to Request Medical Examination of Defendant. Mr. Perino appreciates the extra time to answer so that the Defense can have the benefit of discussing what testing the retained forensic psychiatrist feels is in order for Mr. Perino. Although what medical tests the Government contemplates have not been specified, the Defense will not oppose any medical testing the Government wants to pursue. Indeed, the Defense will want to have some neurological testing done as well. The Defense is in the process of contacting the assigned prosecutor (this takes a little longer than normal to arrange, given this writer's and his schedules, that his office is several time zones ahead of Arizona's, and he apparently works on /// /// IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, No. CR-04-1071-PHX-FJM RESPONSE TO GOVERNMENT'S MOTION TO REQUEST MEDICAL EXAMINATION OF DEFENDANT

Case 2:04-cr-01071-REJ

Document 23

Filed 08/31/2005

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1 cases in various parts of the country) to discuss whether there can be shared testing 2 protocols, so as to avoid duplication and delay. 3 4 5 6 7 8 Copy of the foregoing mailed 10 through the U.S.Mails this 31st day of August, 2005, to 11 CLARENCE BUTLER 12 Assistant U.S. Attorney 5400 Federal Plaza, Ste 1500 13 Hammond, IN 46320 14 16 17 18 19 20 21 22 23 24 25 26 27 28 2 JAMES D. PERINO 15 Defendant s/Donna Lee Elm 9 Respectfully submitted: August 31, 2005. JON M. SANDS Federal Public Defender s/Donna Lee Elm DONNA LEE ELM Asst. Federal Public Defender

Case 2:04-cr-01071-REJ

Document 23

Filed 08/31/2005

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