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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

LAW OFFICES OF MICHAEL J. BRESNEHAN, P.C. Michael J. Bresnehan, Esquire 1761 East McNair Drive, Suite 101 Tempe, AZ 85283-5002 480-345-7032 [email protected] State Bar No.: 009415 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, Plaintiff, vs. KINDY JONAGAN, Defendant.

Case No.: CR-04-00820-PHX-FJM MOTION TO WAIVE DEFENDANT JONAGAN'S PRESENCE AT SUPPRESSION HEARING AND STATUS CONFERENCE (Assigned to Hon. Frederick J. Martone)

COMES NOW the defendant, Kindy Jonagan, by and through the undersigned attorney, and hereby moves this Court for leave to waive her appearance at the Suppression Hearing scheduled for Friday, December 9, 2005 at 3:00 P.M. and the Status Conference that is scheduled to follow at 4:00 P.M. The suppression hearing does not pertain to evidence relevant to any of the Counts involving defendant, Jonagan. Moreover, due to work-related obligations, Ms. Jonagan would prefer to waive her presence at the Status Conference, which will be attended by her attorney. It is not expected that excludable delay under Title 18 U.S.C. §3161(h)(1)(F) will occur as a result of this motion or from an order based thereon. RESPECTFULLY SUBMITTED, this 7th day of December, 2005.

Case 2:04-cr-00820-FJM

Document 191

1

Filed 12/07/2005

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
s/ Michael J. Bresnehan

MICHAEL J. BRESNEHAN, P.C.

s/ Michael J. Bresnehan Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on December 7, 2005, 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: Bruce Blumberg, Rachel Hernandez, Gary Restaino, Jeanette Alvardo, Thomas Hoidal, Ivan Mathew, Gregory Parzych and the Honorable Frederick J. Martone. I hereby certify that on December 7, 2005, I served a courtesy copy of the attached document by COURIER SERVICE on the following: Honorable Frederick J. Martone.

Case 2:04-cr-00820-FJM

Document 191

2

Filed 12/07/2005

Page 2 of 2