Free Motion to Transport Defendant - District Court of Arizona - Arizona

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MICHAEL B. BERNAYS State Bar No. #007057 3839 N. 3rd Street, Suite 400 Phoenix, Arizona 85012 Phone: 602-254-5544 Fax: 602-254-9263 E-mail: [email protected] Attorney for Defendant Sheila Isabell UNITED STATED DISTRICT COURT DISTRICT OF ARIZONA

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UNITED STATES OF AMERICA
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Plaintiff,
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vs.
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SHEILA M. ISABELL, et al.,
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Defendant
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) ) ) ) ) ) ) )

Case No.:

CR 03-1082-001-PHX-MHM

MOTION FOR AMENDED ORDER FOR PROVISION OF TRANSPORTATION

Defendant, Sheila M. Isabell, through counsel, Michael B. Bernays, hereby moves the
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Court for an Amended Order for Provision of Transportation Expenses which explicitly orders
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the Marshall service to provide air transportation for Ms. Isabell's trip to Arizona from Ohio.
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Counsel previously detailed in the Motion to Continue Sentencing filed June 8, 2007, Docket
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No 88, that Ms. Isabell is medically unable to travel by bus for the distance involved to get here
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from Ohio. Counsel has, since the filing of that Motion to Continue, received confirmation
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from Ms. Isabell's doctor that she is unable to travel by bus. A copy of that statement is
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attached hereto as Exhibit A. Though the Court issued an order to provide expenses for
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transportation, that order did not specifically direct the Marshall's Service to provide air
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transportation. Counsel would, based upon the foregoing, move the Court to issue the
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amended order which is submitted contemporaneously herewith which specifically directs the Marshall's Office to provide air transportation.

Case 2:03-cr-01082-MHM

Document 92

Filed 08/01/2007

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RESPECTFULLY SUBMITTED this1st day of August, 2007.
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s/ Michael B. Bernays Michael B. Bernays 3839 N. 3rd Street, Suite 400 Phoenix, Arizona 85012 Attorney for Defendant

Copy of the foregoing e-mailed Via CM/EFC this 1st day of August, 2007, to: John Lopez Assistant U.S. Attorney 40 North Central Avenue, Ste. 1200 Phoenix, AZ 85004-4408 By: s/ Michael B. Bernays

Case 2:03-cr-01082-MHM

Document 92

Filed 08/01/2007

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