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 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 PROVISION OF TRANSPORTATION EXPENSES

Defendant, Sheila M. Isabell, through counsel, Michael B. Bernays, and pursuant to 18
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USC § 4285, hereby moves the Court to order that the United States Marshal Service arrange
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for and pay for Ms. Isabell's non-custodial transportation from Chillicothe, Ohio, to Phoenix,
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Arizona, for the purposes of Ms. Isabell attending her sentencing on June 11, 2007, at
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3:30 p.m. in the above captioned case. Counsel would urge the Court to find that it is
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Ms. Isabell's affidavit of indigency which resulted in the appointment of undersigned counsel
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pursuant to the Criminal Justice Act is sufficient evidence of Ms. Isabell's indigency to justify
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the granting of an order pursuant to this motion. Counsel would further move the Court to
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order the Marshal's Service to furnish Ms. Isabell with subsistence expenses for her travel
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pursuant to law. Counsel has contacted Assistant United States Attorney, John Lopez, who
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has authorized counsel to state that the government does not oppose this motion. Excludible delay pursuant to 18 USC § 3161(h)(1)(H) will occur as a result of this motion being filed.

Case 2:03-cr-01082-MHM

Document 86

Filed 05/31/2007

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RESPECTFULLY SUBMITTED this 30th day of May, 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 30th day of May, 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 86

Filed 05/31/2007

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