Free Motion for Release from Custody - 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 Attorney for Defendant
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'S SUPPLEMENT TO MOTION FOR RELEASE (Assigned to The Honorable David G. Campbell)

EXPEDITED RULING REQUESTED

Defendant, Robert McKay, through undersigned counsel hereby submits this supplement to his request for release by informing the Court that Mr. McKay was informed today that his family will be transferring his mother into hospice tomorrow, Thursday, September 1, 2005. The original motion had anticipated that Mrs. McKay had months to live. That appears to have been shortened substantially. Mr. McKay asks that this matter be set as expeditiously as feasible. RESPECTFULLY SUBMITTED this 31st day of August, 2005.

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Barbara L. Hull, Attorney for Mr. McKay Original electronically filed this date.

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Case 2:03-cr-01167-DGC

Document 797

Filed 08/31/2005

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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 Timothy Duax, Esq. Assistant U.S. Attorney Two Renaissance Square, Suite 1200 40 North Central Avenue Phoenix, Arizona 850034-4408

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Case 2:03-cr-01167-DGC

Document 797

Filed 08/31/2005

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