Free Motion to Transport Defendant - 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

CROWE & SCOTT, P.A.
1100 E. Washington St. Suite 200 Phoenix, Arizona 85034-1090 Telephone (602)252-2570 Facsimile (602) 252-1939 Email: [email protected] Tom Crowe (#002180) Attorneys for Defendant

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, ) ) Plaintiff, ) v. ) ) Kim Houston, ) ) Defendant. ) _____________________________________) No. CR03-00881-003-PHX-FJM
MOTION FOR ORDER DIRECTING U.S. MARSHAL TO TRANSPORT DEFENDANT FOR DEATH VISIT

Defendant, Kim Houston, by and through counsel undersigned, moves this Court for an order directing the U.S. Marshal to transport the Defendant to visit his grandfather, Herbert Houston, who is presently hospitalized in ICU at the Kindred Hospital Arizona in Phoenix. Herbert Houston is suffering from lung cancer and is expected to survive for only a limited period of time. As the Court is aware, the Defendant came from a dysfunctional home. The Defendant was very close to his grandfather who helped raise him during times when his mother and father were unable or unwilling to do so. A limited visit - - not exceeding one hour - - is

requested to be ordered on a hardship basis. Defendant has no history of violence and does not present a security risk. Based on the foregoing Defendant moves for an order directing the U.S. Marshal to transport the Defendant to Kindred Hospital Arizona, 40 E. Indianola, Phoenix, Arizona 85012, 602-280-7000 for purposes of a visit with Herbert Houston.

Case 2:03-cr-00881-FJM

Document 102

Filed 11/09/2007

Page 1 of 2

1 2

DATED this 9th day of November, 2007. CROWE & SCOTT, P.A.

3 4

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

s/ Tom Crowe Tom Crowe 1100 East Washington, Suite 200 Phoenix, Arizona 85034-1090 Attorneys for Defendant

Case 2:03-cr-00881-FJM

Document 102

Filed 11/09/2007

Page 2 of 2