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

MICHAEL S. REEVES, ESQ. State Bar Number: 010420 1212 East Osborn Phoenix, Arizona 85014 Tel: [602] 604-7577 Fax: [602] 604-7555 Attorney for Ronald Holt UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Securities Exchange Commission Plaintiff ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CV 03-1825 PHX- PGR CV03-1826-PHX-PGR CV03-1302-PHX-PGR

MOTION TO FURLOUGH DEFENDANT

Vs. Ronald Holt, et al Defendants.

Ronald Holt, by and through undersigned counsel, hereby requests that the Court allow the Defendant Ronald Holt to be furloughed from incarceration from the current location at CCA in Florence, Arizona, immediately and until such time as the Court holds argument on whether the settlements reached in this and related cases cures Mr. Holt's contempt. No date has yet been set for such a hearing, but will be requested as soon as soon as the CFTC finishes its internal review process for filing the settlement. The purpose for the furlough would be to allow Defendant to be with his family during the holiday season. As the Court can imagine, this case has been a huge strain on Mr. Holt's family and his marriage. Defense counsel has spoken with attorneys for the Commodities Futures Trading Commission and the Securities Exchange Commission. Neither agency is willing to give voice to a vote of no opposition. Also, as Mr. Holt as previously been allowed to travel to California, he again seeks

Case 2:03-cv-01826-PGR

Document 107

Filed 12/12/2005

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

permission to travel to California during a portion of the furlough. WHEREFORE, it is requested that the Court issue an order furloughing Defendant Ronald Holt from the custody of CCA, with permission to travel to California, immediately and until after the first of the new year when a hearing can be set to review the various settlements. Dated: December 12, 2005 /s/ MICHAEL S. REEVES, Attorney for Defendant Ronald Holt

CERTIFICATE OF SERVICE I hereby certify that on this date, December 12, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: Marshall Gandy Merwin D. Grant Patrick M. Murphy by: /s/ Michael S. Reeves

I hereby certify that on December 12, 2005, I served the attached document by U.S. mail and/or e-mail on the following, who are not registered participants of the CM/ECF System: Timothy J. Mulreany, Chief Trial Attorney Karon Powell, Trial Attorney Division of Enforcement 1155 21st Street, NW Washington, D.C. 20581 Attorneys for the Commodities Future Trading Commission Warfield & Company, CPAs 14555 North Scottsdale Rd., #340 Scottsdale, Az 85254 Receiver Thomas M. Connelly, Esq. 2425 East Camelback Road, Suite 880 Phoenix, Az 85016-4208 Susanne Ingold, Esq. Burch & Cracchiolo, PA 702 East Osborn Rd., #200 P.O. Box 16882 Phoenix, AZ 85011-6882 by: /s/ Michael S. Reeves

2
Case 2:03-cv-01826-PGR Document 107 Filed 12/12/2005 Page 2 of 2