Free Other Notice - District Court of Arizona - Arizona

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Barbara Hull, State Bar No. 011890 86 West University Drive, Suite 101A Mesa, Arizona 85201 Telephone: (480)834-0002 Facsimile: (480)834-0003 [email protected] Attorney for Defendant Robert McKay
IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. ROBERT MCKAY, Defendant.

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Case No.: CR-03-1167-16-PHX-DGC DEFENDANT ROBERT McKAY'S REQUEST REGARDING REVIEW OF RELEASE CONDITIONS (Assigned to The Honorable David G. Campbell)

On Tuesday, September 6, 2005, this Court entered its Order directing that Mr. McKay be temporarily released from detention for a period of two weeks in order that he might travel to Illinois to be with his ailing mother. Mr. McKay was released from CCA at noon on Wednesday, September 7, 2005. For the Court's information, Mrs. McKay passed away on Saturday, September 10, 2005, within two days of her son's arrival in Illinois. This Court's Order also directs that Mr. McKay report back to the Marshall's Office in Phoenix by 5:00 p.m. on Tuesday, September 20, 2005. Mr. McKay has made flight arrangements to return to Phoenix on Sunday, September 18, 2005 in order to comply with that directive. With the Court's permission, Mr. McKay offers to appear before this Court prior to his self-surrender date and time, at a time convenient to the Court, in order
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Case 2:03-cr-01167-DGC

Document 814

Filed 09/15/2005

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to demonstrate his obedience to this Court' s rulings. This offer is made, in part, in hopes that this will assist the Court in rendering its decision whether, and if so under what conditions, to extend Mr. McKay' s release pending trial pursuant to Mr. McKay' s previous motion. Regardless of this Court' s decision in this matter, Mr. McKay is very grateful for this solemn, yet paramount opportunity to see his mother prior to her passing. If no appearance is scheduled, Mr. McKay will report to the Marshall' s office at or prior to the time specified. It is not anticipated that excludable delay will occur pursuant to 18 U.S.C. §3161(h)(8)(A) as a result of this pleading or any resultant Order. RESPECTFULLY SUBMITTED this 15th day of September, 2005.

____/S/___Barbara L. Hull_______________

Barbara L. Hull, Attorney for Mr. McKay Original electronically filed this date. Courtesy copy of the foregoing Motion delivered electronically this date to: The Honorable David G. Campbell United States District Court 401 West Washington Street Phoenix, Arizona 85003-0001 at [email protected] Timothy Duax, Esq. Assistant U.S. Attorney Two Renaissance Square, Suite 1200 40 North Central Avenue Phoenix, Arizona 850034-4408 at [email protected] ___/S/_________________________

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Case 2:03-cr-01167-DGC

Document 814

Filed 09/15/2005

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