Free Response to Motion - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona KEVIN M. RAPP Assistant U.S. Attorney Arizona State Bar No. 014249 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, Plaintiff, v. Javier Leon-Rodriguez, Defendant. Comes Now, the United States of America, by through and undersigned counsel, and hereby objects to the defense motion requesting an order permitting defendant Leon-Rodriguez to travel from Calexico, California, September 8, 2006 to Mexicali BC for the purpose of examining books and records of his business, meeting with his administrator and employees and inspecting the business. The Defendant pleaded guilty to conspiracy to possess with the intent to distribute marijuana from Mexico. Accordingly, the Defendant should not be allowed to travel to Mexico to conduct business activities. Moreover, the Defendant's request can be accomplished by having the books and records brought to the United States. And the administrator can travel to the United States to meet with the Defendant. Based upon the Defendant's conviction and the fact that his request can be accomplished in the United States, the government objects to the defense motion to modify conditions of supervised release. GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION TO MODIFY CONDITIONS OF SUPERVISED RELEASE CR-02-354-PHX-FJM

Case 2:02-cr-00354-FJM

Document 257

Filed 08/23/2006

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Lastly, the undersigned counsel has spoken with the Defendant's Supervising Probation

2 Officer, Michael Watts, he also objects to the defendant's request for the same reasons. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 S/ Raquel Lopez 17 18 19 20 21 22 23 24 25 26 27 28 2
I hereby certify that on August 23, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Alfred S. Donau, III Attorney for Defendant

Respectfully submitted this 23rd day of August, 2006. PAUL K. CHARLTON United States Attorney District of Arizona S/Kevin M. Rapp KEVIN M. RAPP Assistant U.S. Attorney

Case 2:02-cr-00354-FJM

Document 257

Filed 08/23/2006

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