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

1 PHIL NOLAND
Attorney #010394

2 Luhrs Tower - Suite 403
45 West Jefferson Street

3 Phoenix, AZ 85003-2314
(602) 252-1099

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Attorney for Jesse Robledo-Alvarez

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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, ) ) ) ) ) ) ) ) ) ) )

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CR04-00954-001-PHX-MHM SECOND MOTION TO MODIFY RELEASE CONDITIONS (Unopposed)

Plaintiff,
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v.
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Jesse Alvarez-Robledo,
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Defendant.

Jesse Alvarez-Robledo, through counsel, requests this court to order his release
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conditions be modified to allow him to travel to California for work-related matters, pursuant
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to 18 U.S.C. 3142.
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Mr. Robledo is employed doing refrigeration repair. As part of his work, he needs to
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travel from Yuma, across the bridge over the Colorado River, to Winterhaven, California..
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Counsel has contacted both Pretrial Services Officer Ruben Salgado and Assistant U.S.
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Attorney John Boyle, and neither oppose Mr. Robledo's release conditions being modified to
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allow him to travel to California for work-related purposes.
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Excludable delay pursuant to 18 U.S.C. § 3161 should not occur since Mr. Alvarez24

Robledo has entered into a plea agreement. Should such delay occur, though, it is in the best
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interest of the public and Mr. Robledo.
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PHIL NOLAND Luhrs Tower, Suite 403 45 W. Jefferson Street Phoenix, Arizona 85003 (602) 252-1099

Case 2:04-cr-00954-MHM

Document 71 1 Filed 08/24/2005

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Respectfully submitted this
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PHIL NOLAND Luhrs Tower, Suite 403 45 W. Jefferson Street Phoenix, Arizona 85003 (602) 252-1099

day of August, 2005.

/s/ PHIL NOLAND Attorney for Mr. Alvarez-Robledo

Case 2:04-cr-00954-MHM

Document 71 2 Filed 08/24/2005

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