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

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LAW OFFICE OF DAVID L. LOCKHART
A PROFESSIONAL CORPORATION ATTORNEY and COUNSELLOR at LAW

3216 N. Third Street, 3rd Floor Phoenix, Arizona 85012 [email protected] _____________

(602) 424-6105 Fax (602) 248-2916

David L. Lockhart State Bar No. 018475 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. MICHAEL CRAIG ANDERSON, Defendant. No. CR 04-01281-001-PHX-DGC MOTION TO TRAVEL

DEFENDANT MICHAEL CRAIG ANDERSON, by and through undersigned counsel, respectfully moves this Honorable Court for an Order granting him permission to travel with his wife, Gina Anderson, the co-defendant in this matter, to Las Vegas, Nevada to attend an Escape International convention from April 28 to May 1, 2006. Both Mr. Anderson and his wife have hotel reservations at the MGM Grand Hotel. Mr. Anderson plans on returning to the state of Arizona the morning of May 1, 2006. Undersigned has contacted Assistant United States Attorney John Boyle regarding Defendant's requests and avows that Mr. Boyle has no objection to Mr. Anderson traveling to Las Vegas. Further, undersigned avows that he has contacted, Ruben Salgado, the Defendant's assigned

Case 2:04-cr-01281-DGC

Document 106

Filed 04/20/2006

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pre-trial services officer in Yuma, Arizona, and Mr. Salgado has no objection to the requests made herein. For the reasons contained herein, undersigned counsel, respectfully requests that this Honorable Court grants this motion and enter an Order modifying the prior release Order allowing Defendant Michael Anderson to travel outside the state of Arizona to Las Vegas, Nevada for the purposes of attending the Escape International. Excludable delay under 18 U.S.C. §3161(h)(1)(F) and 8(A) will not occur as a result of this Motion or an Order based thereon. RESPECTFULLY SUBMITTED this 20th day of April, 2006.

LAW OFFICE OF DAVID L. LOCKHART

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By

s/David L. Lockhart David L. Lockhart, Esq. 3216 North Third Street, 3rd Floor Phoenix, AZ 85012-2682 Attorneys for Defendant

CERTIFICATE OF SERVICE I certify that on April 20, 2006, I electronically transmitted this 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: Clerk of the Court The Honorable David G. Campbell United States District Court Judge 401 W. Washington Phoenix, Arizona 85003 John Z. Boyle, Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408 Patricia A. Gitre, Esq. 331 N. First Avenue, Suite 150 Phoenix, Arizona 85003 Attorney for co-defendant Gina D. Anderson By: s/Carol Rosales

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