Free Stipulation - District Court of Arizona - Arizona

Douglas C. Erickson, No. 012130 MAYNARD CRONIN ERICKSON 2 CURRAN & SPARKS, P.L.C. 1800 Great American Tower 3 3200 North Central Avenue Phoenix, Arizona 85012 4 (602) 279-8500
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MAYNARD CRONIN ERICKSON CURRAN & SPARKS, P.L.C.

Attorneys for Defendant UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. GEOFFREY HULIN, Defendant. On December 13, 2006, Defendant, Geoffrey Hulin, moved the Court to terminate or modify the terms of his probation. The government responded, and Mr. Hulin replied, supplying additional information to the government and the Court. On February 2, 2007, the Court held a hearing on said motion and also heard from the United States Probation Office concerning its recommendations. Following that hearing, the Court indicated that counsel should attempt to stipulate to an appropriate modification. Mr. Hulin, through his counsel, and the United States, through its counsel, hereby stipulate that the Court should modify the existing terms of probation as follows. Standard Term 2 should be modified to allow the defendant to travel in and between Arizona, Nevada, and California for the purpose of training and competing in golf tournaments and attending the PGA Qualifying School. Standard Term 6 should be modified to provide that in lieu of work, the defendant is permitted to devote substantially all of his work time and effort to training and competing in golf tournaments and attending the PGA Qualifying School.
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3200 NORTH CENTRAL AVENUE · SUITE 1800 · PHOENIX, ARIZONA 85012

No. CR04-277-PHX-EHC STIPULATION TO MODIFY TERMS OF PROBATION

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TELEPHONE 602.279.8500 · FACSIMILE 602.263.8185

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ATTORNEYS AT LAW

Case 2:04-cr-00277-EHC

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Special Condition 4 is modified to provide that in lieu of being "gainfully employed," the defendant may train for and compete in golf tournaments and attend the PGA Qualifying School. He shall report the dates and results of all tournaments played, as well as his weekly practice schedule, to the probation officer at least once a month. If defendant is accepted and attends the PGA Qualifying School, he shall submit proof of his enrollment and participation. DATED this 15th day of February, 2007 MAYNARD CRONIN ERICKSON CURRAN & SPARKS, P.L.C. By s/Douglas C. Erickson Douglas C. Erickson 1800 Great American Tower 3200 Central Avenue Phoenix, Arizona 85012 Attorneys for Defendant UNITED STATES ATTORNEY By s/Glenn B. McCormick Glenn B. McCormick, Esq. Two Renaissance Square 40 N. Central, Suite 1200 Phoenix, AZ 85004-4408 ORIGINAL of the foregoing filed this 15th day of February 2007via ECF with:

Clerk of the Court United States District Court 18 401 W. Washington Phoenix, AZ 85003
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with a copy mailed (along with a copy of the NEF) and electronically mailed this same day to:

Honorable Earl H. Carroll United States District Court 401 W. Washington 22 Phoenix, AZ 85003 [email protected]
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with a copy mailed this same day to:

Mark Nebgen 401 W. Washington St., SPC 7 3 Suite 160 Phoenix, AZ 85003-2119
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By

s/Stacey Tanner

F:\CLIENTS\HULIN11.975\PLDGS\Stipulation.wpd

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