Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona


File Size: 17.2 kB
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Date: May 30, 2006
File Format: PDF
State: Arizona
Category: District Court of Arizona
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Gail Gianasi Natale State Bar No. 010389 817 North Second Street Phoenix, AZ 85004 (602) 258-1778 Attorney for Defendant UNITED STATES DISTRICT COURT

5 DISTRICT OF ARIZONA 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 v. CHARLOTTA KAYE LEWIS, Defendant. COMES NOW Defendant CHARLOTTA KAYE LEWIS, by and through counsel undersigned, and respectfully moves this Court for an Order that when she is transported for her status hearing on Thursday, June 1, 2006, that CCA be asked to bring her "bag and baggage" to court. Defendant understands that whether she is released will be determined by the Hon. Edward C. Voss but she also believes that an arrangement may be worked out with the United States Attorney's Office and Leigh Anne Gibbons, Ms. Lewis' assigned probation officer. In the event that the AUSA, Ms. Gibbons and UNITED STATES OF AMERICA, Plaintiff, MOTION FOR `BAG AND BAGGAGE' Case No. CR 04-00176-001-PHXRGS

the Court agree that the Defendant may be released she asks that her clothing and personal effects be brought to court with her. If the Court releases Ms. Lewis it will be much easier for her to leave the Marshal's office if her clothing is brought to court with her. If, on the other hand, Judge Voss

Case 2:04-cr-00176-RGS

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determines to keep Ms. Lewis in custody, the Marshal Service simply can return her clothing and effect with her to CCA. Excludable delay under 18 U.S.C. ยง 3161(h) is not expected to occur as a result of this motion or of an Order based thereon. RESPECTFULLY SUBMITTED this 30th day of May, 2006.

s/Gail Gianasi Natale GAIL GIANASI NATALE Attorney for Defendant

I hereby certify that on May 30, 2006 I electronically transmitted the attached document to the Clerk's Office using the CM/ECF registrants: Assistant U.S. Attorney Mary Beth Pfister COPIES of the foregoing mailed this 30th day of May, 2006, to: Charlotta Kaye Lewis #81726-008 CCA-Florence P.O. Box 6300 Florence, AZ 85232 Informational copy mailed to:

19 Leigh Anne Gibbons,U.S. Probation Officer 20 21 22 23 24 25 26 2 s/Carole Hutchison

Case 2:04-cr-00176-RGS

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