Free Motion to Modify Conditions of Release - District Court of Arizona - Arizona

Martin Lieberman, #007442 MARTIN LIEBERMAN, P.C. 2 111 W. Monroe, Suite 1650 Phoenix, Arizona 85003 3 [email protected] Telephone: (602) 254-5544 4 Fax: (602) 254-9263
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IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA ) ) United States of America, ) ) ) Plaintiff, ) ) vs. ) ) ) Allan Guttentag (04) ) ) Defendant. _____________________________ ) CR04-0539 PHX-MHM MOTION TO MODIFY CONDITIONS OF RELEASE [Hon. Mary Murguia]

The Defendant, Allan Guttentag, hereby moves to modify the conditions of his release to permit him to travel within the contiguous United States. Mr. Guttentag has been restricted to the States of Arizona and California since the inception of this case. On May 1, 2006, Mr. Guttentag entered a plea of guilty before Magistrate Judge Anderson. His plea requires him to cooperate with the government. Sentencing is scheduled for August 7, 2006, unless the existing co-defendants do not resolve their cases with the government. In that event, sentencing will be continued. Given the length of time Mr. Guttentag has been supervised by pre-trial services, the excellent record of his compliance (made available to counsel for the defendant and the government at the change of plea proceedings), and Mr. Guttentag's cooperation with the government, it is respectfully requested that Mr. Guttentag be permitted to travel within the United States without first having to obtain permission from his pre-trial services officer. This will allow him to take

Case 2:04-cr-00539-MHM

Document 106

Filed 05/11/2006

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short, unplanned trips to Nevada or Oregon if he wishes during the summer months. Assistant United States Attorney Howard Sukenic does not oppose this request. Excludable delay under 18 U.S.C. §3161(h)(1)(f) will occur as a result of this motion or an order based thereon. RESPECTFULLY SUBMITTED this 11th day of May , 2006. MARTIN LIEBERMAN, P.C. /s/ Martin Lieberman By: Martin Lieberman, #007442 111 W. Monroe, Suite 1650 Phoenix, Arizona 85003 Attorney for Defendant Allan Guttentag

I hereby certify that on May 11, 2006, I electronically transmitted the attached document to the Clerk's Office using the ECF system for filing and transmittal of Notice of Electronic Filing to all ECF registrants associated with this case. /s/ C. Woodruff

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Case 2:04-cr-00539-MHM

Document 106

Filed 05/11/2006

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