Free Reply to Response to Motion - District Court of Arizona - Arizona

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Law Office of

273 S. Scott Avenue Tucson, Arizona 85701 (520) 884-1234 [email protected] AzBar:009144
Attorney for Claimants

RICHARD B. JONES

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) Plaintiff, ) v. ) ) (1) $493,850 in U.S. Currency, and ) (2) One 1993 Ford F-350 Truck, ) ) Defendants. ) ******************************** ) Roy Bruno, and ) Miguel Camacho, ) Claimants. ) ) UNITED STATES OF AMERICA, CV03-2345 PHX VAM CLAIMANTS' REPLY RE: STAY OF JUDGMENT PENDING APPEAL

Claimants, through counsel, hereby reply to the Government's response to the motion for stay as follows. Given the costs already associated with the storage of the 1993 Ford F-350, the obvious additional costs to be incurred during the pendency of the appeal, as well as the asset's negligible value, counsel hereby withdraws the request to stay enforcement of the judgment as it relates to the truck. As to the currency, while a stay possibly may be unnecessary given the state of the law, there is also no reason not to grant a stay. Counsel believes the claimants have a duty to take steps to preserve the property pending appeal as well as a statutory right to do so.

Case 2:03-cv-02345-VAM

Document 69

Filed 02/03/2006

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RESPECTFULLY SUBMITTED February 3, 2006. s/ Richard B. Jones Attorney for Defendant Certificate of Service I hereby certify that on February 3, 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: · Reid Pixler, Assistant United States Attorney And a paper copy was delivered to: · The Honorable Virginia Mathis (w/NEF)

Case 2:03-cv-02345-VAM

Document 69

-2Filed 02/03/2006

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