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 [email protected] Two Renaissance Squ are 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, CR-02-354-PHX-FJM Plaintiff, v. Pedro Leon Rodriguez, Defendant. Comes now, the government by and through undersigned counsel, and hereby responds to the defendant's motion for an Order terminating halfway house payment. The defendant requests that his payment to the halfway house be terminated due to the change in financial circumstances that were caused, in part, by personnel working on behalf of the Bureau of Prisons. The undersigned attorney has spoken to Matthew Kritter, Management Center GOVERNMENT'S RESPONSE TO DEFENDANT'S MOTION FOR ORDER TERMINATING HALFWAY HOUSE PAYMENT

Adm inistrator, Bureau of Prisons, and has been advised that the defendant is an Intensive Confinement Center Bootcamp graduate and has been compliant with his release terms thus far. Moreover, the undersigned attorney was further advised that they have no objection to a waiver of his subsistence payments to the halfway house. Accordingly, the government has no objection to the defendant's payment to the halfway house being terminated.

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Case 2:02-cr-00354-FJM

Document 254

Filed 08/05/2005

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Excludable delay under 18 U.S.C. § 3161(h) may occur as a result of this motion or an order based thereon. Respectfully submitted this 5th day of August, 2005. PAUL K. CHARLTON United States Attorney District of Arizona S/ KEVIN M. RAPP Assistant U.S. Attorney

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CERTIFICATE OF SERVICE I hereby certify that on August 5, 2005, I served the attached document by mail on the following, who is not a registered participant of the CM/ECF system: Alfred D. Donau III DONAU & BOLT Suite 501 3505 North Campbell Avenue Tucson, Arizona 85719-2033 Attorney for Pedro Leon-Rodriguez

Case 2:02-cr-00354-FJM

Document 254

Filed 08/05/2005

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