Free Motion to Modify Conditions of Release - District Court of Arizona - Arizona

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Anders Rosenquist Jr., Bar No. #002724 ROSENQUIST & ASSOCIATES ATTORNEYS AT LAW 80 East Columbus Phoenix, AZ 85012 TELEPHONE: (480) 488-0102 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, v. NEIL RUSTY BOND, Defendant. MOTION TO MODIFY CURRENT RELEASE ORDERS TO ALLOW DEFENDANT TO TRAVEL OUT OF STATE (expedited ruling requested) No. CR 03-0974-PHX-DGC

Defendant, Neil Rusty Bond, through undersigned counsel, hereby requests the Court allow him to travel out of state, while his appeal is pending. On March 31, 2006, the Court granted Defendant's Motion for Release Pending Appeal, and ordered Defendant to comply with the pretrial release conditions previously imposed in his case. Subsequently, this Court issued an order on May 24, 2006 that Defendant no longer had to wear an ankle bracelet, nor comply with the normal conditions of release associated with wearing an ankle bracelet. Defendant's Pretrial Services probation officer, Michelle Bertinetti (602-322-7395), has no objection to this request as long as Defendant clears it with her, tells her where he is going, time of stay, and contacts her upon his arrival and return.

Case 2:03-cr-00974-DGC

Document 223

Filed 09/13/2006

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WHEREFORE, Defendant respectfully requests this Court allow him to travel out of state while his appeal is pending.

RESPECTFULLY SUBMITTED this 13th

day of September 2006.

ROSENQUIST & ASSOCIATES

By:

/s/ Anders Rosenquist Anders V. Rosenquist Attorney for Defendant

ORIGINAL filed this 13th day of September 2006 with: Office of the Clerk Arizona District Court COPY submitted this 13th day of September 2006 to: Honorable David G. Campbell Arizona District Court Michelle Rae Hamilton-Burns U.S. Attorney's Office Two Renaissance Square 40 N. Central Avenue, STE 1200 Phoenix, Arizona 85004 Counsel for Plaintiff Neil Rusty Bond 4132 E. Alan Lane Phoenix, Arizona 85028 By: /s/ Florence M. Bruemmer

Case 2:03-cr-00974-DGC

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Filed 09/13/2006

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