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

HENRY J. FLORENCE, LTD. Henry J. Florence 45 West Jefferson 10th Floor, Luhrs Tower Phoenix, Arizona 85003 (602) 258-8451 Bar No. 001524 Attorney for Defendant - Jose Luis German THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA Plaintiff, vs. JOSE LUIS GERMAN, Defendant. ) ) ) ) ) ) ) ) ) ) No. CR 02-01179-003-PHX-PGR MOTION TO ALLOW TRAVEL

(Assigned to the Hon. Rosenblatt)

The Defendant, by and through undersigned Counsel, hereby requests this Court to modify his conditions of probation pursuant to 18 § 3563 (c) of the Federal Rules of Criminal Procedure. Defendant requests that he be allowed to travel to New York to pick up his 94 year old mother, and move her to the Dominican Republic. Defendant will be making all of her arrangements with the nurses and house where she will be staying. Defendant is to depart on July 21, 2008, and return August 4, 2008. Mr. German will be staying at the Sabana Grande de Palenque Avenida, A #29, San Cristobal, Republica Dominicana, and will be reachable at phone number 809-7769177. Defendant has abided by all terms of probation and will check in with this office upon his return should the Court deem necessary. Counsel therefore respectfully requests that Defendant's probation be modified to allow this travel. RESPECTFULLY SUBMITTED, this 15th s:/Henry J. Florence Henry Florence Attorney for Defendant day of May, 2008.

Case 2:02-cr-01179-PGR

Document 149

Filed 05/15/2008

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