Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2749 5 GERALD A. WILLIAMS, #013115 Asst. Federal Public Defender 6 Attorney for Defendant 7 [email protected] IN THE UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 vs. Nichole Wesley Cassadore, Defendant. The defendant, by and through undersigned counsel, respectfully moves for a Court order directing the U.S. Marshal Office to escort Ms. Nichole Cassadore to the Phoenix Children's Hospital's Intensive Care Unit to visit her daughter Nila United States of America, Plaintiff, No. CR-02-395-PHX-ROS MOTION FOR MARSHAL ESCORT (Expedited Ruling Requested) DISTRICT OF ARIZONA

21 Cassadore. Nila Cassadore is terminally ill as a result of cancer. Nichole Cassadore 22 wishes to visit her daughter at this time should her daughter not survive this current 23 hospital stay. Given the exigency of the circumstances, an expedited ruling is 24 respectfully requested. 25 26 27 28 ... ... ...

Case 2:02-cr-00395-ROS

Document 124

Filed 03/13/2006

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It is expected that excludable delay under Title 18 U.S.C. Section

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: March 13, 2006. 4 JON M. SANDS 5 Federal Public Defender 6 7 8 9 Copy of the foregoing transmitted by CM/ECF for filing this 13th day 10 of March, 2006, to: 11 CLERK'S OFFICE 12 United States District Court Sandra Day O'Connor Courthouse 13 401 W. Washington Phoenix, Arizona 85003 14 15 THOMAS SIMON Assistant U.S. Attorney 16 United States Attorney's Office Two Renaissance Square 17 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 18 19 Copy mailed to: 20 NICHOLE WESLEY CASSADORE Defendant 21 s/Gerald A. Williams 22 \MarshalEscortMTN 23 24 25 26 27 28 s/Gerald A. Williams Asst. Federal Public Defender

Case 2:02-cr-00395-ROS

Document 124

Filed 03/13/2006

Page 2 of 2