Free Admissions of Allegation - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona FREDERICK A. BATTISTA Assistant U.S. Attorney [email protected] Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Maryland State Bar Member Telephone (602) 514-7500

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America,
CR-02-088-PHX-ROS

Plaintiff, v. Carissa Rayann Whitebread, Defendant. Plaintiff, the United States of America, and defendant, Carissa Rayann Whitebread, respectfully request that this Honorable Court enter an order permitting defendant to enter admissions to the allegations contained in the pending Petition to Revoke Supervised Release. The parties are making this request in the interest of judicial economy. Defendant has reviewed the allegations contained in the petition with her attorney and she does not dispute any of the allegations. Defendant is fully aware of the potential consequences of her admissions, i.e., a sentence of imprisonment of up to 51 months, and presently sees no benefit to either party in proceeding with an evidentiary hearing. By proceeding via admissions, the following resources will be conserved, (1) the efforts of an expert in drug analysis will not be required prior to and during the hearing; (2) a representative of TASC will not be required to testify about matters relating to the chain of custody of urine samples, failures to submit urine samples and termination from a substance abuse program, and (3) a probation officer will not be required to
JOINT MOTION TO PROCEED VIA ADMISSIONS

Case 2:02-cr-00088-ROS

Document 87

Filed 08/25/2005

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testify about matters relating to the chain of custody of urine samples and failures to submit urine samples. Upon consideration of all of these facts, the parties agree that the best course of action in this case is for the Court to permit defendant to make admissions to the subject allegations and proceed to a disposition hearing at the Court's convenience. Excludable delay under 18 U.S.C. § 3161 may occur as a result of this motion or of an order based thereon. Respectfully submitted this 25th day of August, 2005. PAUL K. CHARLTON United States Attorney District of Arizona S/ Frederick A. Battista FREDERICK A. BATTISTA Assistant U.S. Attorney S/ John W. Rood, III

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JOHN W. ROOD, III Counsel for Defendant

I hereby certify that on August 25, 2005, I caused the attached document to be electronically transmitted to the Clerk's 18 Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing 19 to the following CM/ECF registrants:
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John W. Rood, III [email protected] Probation Officer Leigh Anne Gibbons U.S. Probation Office s/ Frederick A. Battista FREDERICK A. BATTISTA Assistant U.S. Attorney

Case 2:02-cr-00088-ROS

Document 87

Filed 08/25/2005

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