Free Motion to Strike - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PAUL K. CHARLTON United States Attorney District of Arizona MICHELLE HAMILTON-BURNS Assistant U.S. Attorney Arizona State Bar No. 010269 United States Attorney's Office Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, CR-03-0974-PHX-DGC Plaintiff, v. Neil Rusty Bond, Defendant. The United States of America, by and through its attorney, the United States Attorney for the District of Arizona, moves to strike the following pleadings, filed by defendant, Neil Rusty Bond on his own behalf: Motion for a Newly Appointed U.S. Defense Attorney to Properly Assist in Filing an Appeal and Motion for a Newly Appointed U.S. Defense Attorney to Properly Assist in Representation During an Appeal (Docket 181): Motion for a Newly Appointed U.S. Defense Attorney to Properly Assist in Immediate Filing of a Legal Writ of Habeas Corpus, Along with Legal Representation for Habeas Corpus Based on Ineffective Assistance of Counsel (Docket 180): Defense Motion for Court to Order and Compel Federal Agent, Troy Turk, to Undergo a Polygraph, Regarding Missing and Suppressed Evidence Under the Brady Doctrine (Docket 185): Defense Motions Court to Order and Compel the U.S. Government and Social Security to Produce Records (Docket 186): Defense Motions Court to Order and Compel the U.S. Government to Produce Defendant's Social Security File (Docket 187): Defense Motions the Court to Order and Compel the U.S. Government to Produce Video Tape (Docket 188): and MOTION TO STRIKE DEFENDANT'S PRO SE PLEADINGS

Case 2:03-cr-00974-DGC

Document 191

Filed 03/13/2006

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Defense Motions Court to Order and Compel the U.S. Government to Produce All Social Security/U.S. Treasury Checks Cashed by Defendant (Docket 190) Defendant Bond is currently represented by attorney, Timothy Holtzen. Defendant is not allowed to appear or act on his own behalf until and unless a substitution or withdrawal of counsel occurs. Local Rules of Civil Procedure 83.3(c)(2): Local Rules of Criminal Procedure 57.14. Wherefore it is respectfully requested that this court strike the aforementioned pleadings filed by defendant Bond on his own behalf. It is expected that excludable delay under Title 18, United States Code, Section 3161(h)(1)(F) will occur as a result of this motion or an order based thereon. Respectfully submitted this 13th day of March, 2006. PAUL K. CHARLTON United States Attorney District of Arizona /S Michelle Hamilton-Burns MICHELLE HAMILTON-BURNS Assistant U.S. Attorney

Case 2:03-cr-00974-DGC

Document 191

Filed 03/13/2006

Page 2 of 4

1 2 3 4 5 6 7 CERTIFICATE OF SERVICE 8 9 document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice 10 of Electronic Filing to the following CM/ECF registrants: 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Timothy C. Holtzen [email protected] I hereby certify that on this 13 th day of March, 2006, I electronically transmitted the attached

I hereby certify that on this day, I served the attached document by mail on the following, who are not registered participants of the CM/ECF System: Neil Rusty Bond 4132 E. Alan Lane Phoenix, Arizona 85028 /S Michelle Hamilton-Burns

Case 2:03-cr-00974-DGC

Document 191

Filed 03/13/2006

Page 3 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Case 2:03-cr-00974-DGC

Document 191

Filed 03/13/2006

Page 4 of 4