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

1 Brian F. Russo (018594)
lll West Monroe Street
2 suite 1212
_ Phoenix, AZ 85003
J 602-340-l 133 telephone
W 602-252%-9179 facsimile
4 e-mail: [email protected]
5 Attorney for Defendant Johnston
6 IN THE UNITED STATES DISTRICT COURT
7 DISTRICT OF ARIZONA
a
9 STATE OF ARIZONA, ) Case No. CR 03-1167-PHX-DGC
)
I Plaintiff`, ) MOTION FOR RELEASE OF
N ) PASSPORT AND PORPOSED
vs. ) ORDER
ll )
M ROBERT J. JOHNSTON, JR. (1), g
Defendant. )
I3 y
14 )
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16 COMES NOW the Defendant Robert Johnston, by and through undersigned
17 Counsel and hereby moves this Honorable Court for an order releasing his
N passport. Mr. Johnsotn surrendered his passport as part of his pretrial release
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conditions and has not applied for a new one. Mr. J ohnsotn was sentenced to
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A probation two years probation on December l8, 2006 and has successfully
22 complied with all terms and conditions as set forth by this Court and the Federal
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Probation Officer.
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Case 2:03-cr-01167-DGC Document 1470 Filed O9/O4/2008 Page1 01*2

l The surrender ofhis passport was a condition of pretrial release, which is no
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longer in place. Thus, he respectfully requests that this Court order the release of
4 his passport so he can retrieve it from the Clerk ofthe Court.
ss RESPECTFULLY SUBMITTED this 8m day ofjanuary, 2008.
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7 /s/Brian F. Russo
8 Brian F. Russo
Attorney for Defendant
a
10 COPY ofthe foregoing
electronically mailed
ii Mh day of September, 2008, to:
lz Hon. David G. Campbell
13 Judge the District Court
M Keith Vercauteren
,5 Assistant U.S. Attorney
i6 By:/s/ Michele Cunningham
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Case 2:03-cr-01167-DGC Document 1470 Filed O9/O4/2008 Page 2 of 2

Case 2:03-cr-01167-DGC

Document 1470

Filed 09/04/2008

Page 1 of 2

Case 2:03-cr-01167-DGC

Document 1470

Filed 09/04/2008

Page 2 of 2