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

40 North Central Avenue Phoenix, Arizona 85004-4429 Facsimile No.: (602) 734-3949 Telephone: (602) 262-0222 [email protected] Frederick R. Petti (State Bar No. 011668) Attorneys for Defendant Gary Hirth

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Gary Hirth, Defendant. ) ) ) ) ) ) ) ) ) )

No. CR-03-1280-PHX-RGS DEFENDANT HIRTH'S MOTION FOR EXPEDITED RELEASE OF PASSPORT

Defendant Hirth was sentenced by this Court on August 29, 2005, to a term of probation for 36 months. Prior to that time, Mr. Hirth was on supervised release for nearly two years. During the entire time Mr. Hirth has been under supervised release and probation he has faithfully abided by all conditions imposed by the Court. Mr. Hirth now has the opportunity to take a vacation to Barbados in early February, and he will need his passport to make the trip. Mr. Hirth, at an earlier date, surrendered his passport to this Court. Because Mr. Hirth has faithfully followed all conditions imposed on him by this Court, and because there is no other reason why Mr. Hirth should not be allowed to travel to Barbados in early February, Mr. Hirth requests that the Court release his passport on an expedited basis. RESPECTFULLY SUBMITTED this 18th day of January, 20077. LEWIS AND ROCA LLP

By s/ Frederick R. Petti Frederick R. Petti Attorneys for Defendant Gary Hirth
Case 2:03-cr-01280-RGS Document 63 Filed 01/18/2007 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
Case 2:03-cr-01280-RGS

CERTIFICATE OF SERVICE I hereby certify that on this 18th day of January, 2007, 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: Peter Sexton [email protected] I also certify that on this 18th day of January, 2007, I served the attached document by fax on the following: Ariel Palafox Probation Officer (602) 682-4333 FAX

s/ Sherry Samford

Document 63

2

Filed 01/18/2007

Page 2 of 2
1802910.1