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

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Darius M. Nickerson BURNS, NICKERSON & TAYLOR, PLC 111 W. Monroe, Suite 1500 Phoenix, AZ 85003 (602) 254-0004 Bar #010078 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, ) CR 02-00355-001-PHX-FJM ) ) ) MOTION TO RELEASE PASSPORT ) ) ) ) ) )

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Plaintiff,
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vs.
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Gurvinder S. Takhar, Defendant

Defendant moves this court to release his passport that is currently in possession of the United States District Court Clerk's Office.

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Mr. Takhar was recently successfully discharged from probation on September 8,
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2005 by this court. (See attachment). He is no longer under the supervision of this court. However, the Clerk's office will not release his passport without a court order. Mr. Takhar and his family have recently experienced a family tragedy and consequently are planning to travel immediately. The United States Attorney has been contacted and has no objections to this motion. Michael Wimmer has been contacted and has no objections to this motion.

Case 2:02-cr-00355-FJM

Document 53

Filed 09/21/2005

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Therefore Defendant urges this court to order that the Clerk's office release Defendant's passport to him.

RESPECTFULLY SUBMITTED this 21th day of September 2005.

s/ Darius M. Nickerson Darius M. Nickerson BURNS, NICKERSON & TAYLOR, PLC

Copies of the foregoing emailed this 21th day of September 2005, to: Honorable Fredrick J. Martone 401 West Washington Phoenix, AZ 85003 Steven Larimore Assistant U.S. Attorney 40 North Central Ave., Ste. 1200 Phoenix, AZ. 85004 Michael G. Wimmer U.S. Probation Department

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Case 2:02-cr-00355-FJM

Document 53

Filed 09/21/2005

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Case 2:02-cr-00355-FJM

Document 53

Filed 09/21/2005

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