`
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`
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`Paul J. Cambria, Jr. (NY Bar No.1430909, admitted pro hac vice)
`Erin E. McCampbell (NY Bar No. 4480166, admitted pro hac vice)
`LIPSITZ GREEN SCIME CAMBRIA LLP
`42 Delaware Avenue, Suite 120
`Buffalo, New York 14202
`Telephone: (716) 849-1333
`Facsimile: (716) 855-1580
`pcambria@lglaw.com
`emccampbell@lglaw.com
`Attorneys for Michael Lacey
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
`
`
`United States of America,
`
` Plaintiff,
`vs.
`
`Michael Lacey, et al.,
`
` Defendants.
`
`
`NO. CR-18-00422-PHX-SMB
`
`MOTION FOR LEAVE FOR COUNSEL
`TO APPEAR BY PHONE OR
`VIDEOCONFERENCING AT MARCH
`20, 2023 HEARING
`
`
`
`
`
`
`NOW COMES the Defendant, Michael Lacey, by his attorney of record, to ask the Court
`to grant leave for his lawyer to appear by phone or videoconferencing at the March 20, 2023 Hearing
`in this matter. As good cause therefore, the Defendant submits the following:
`Mr. Lacey’s counsel is currently on trial in Erie County, New York in People v. Martinez, Erie
`Cnty. Sup. Ct. Case No. 01686-2020, defending another client who is charged with murder. The
`trial begins today, March 13, 2023, and is projected to last two weeks. It is not possible to travel to
`and from the District of Arizona for the March 20, 2023 Hearing while on trial in Erie County, New
`York at the same time.
`
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`Case 2:18-cr-00422-DJH Document 1529 Filed 03/13/23 Page 2 of 2
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`Further, because the government has seized the majority of Mr. Lacey’s assets, and the
`limited pool of assets available for trial costs was substantially depleted during the first trial in this
`case, assets necessary for travel and accomodations are in short supply and need to be preserved for
`the upcoming trial.
`The Government does not object to this Motion.
`The Court will find attached a proposed Order.
`RESPECTFULLY SUBMITTED this 13th day of March, 2023,
`
`
`
`
`Paul J. Cambria, Jr.
`LIPSITZ GREEN SCIME CAMBRIA LLP
`
`/s/ Paul J. Cambria, Jr.
`Paul J. Cambria, Jr.
`Attorneys for Michael Lacey
`
`
`
`
`
`
`
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`
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`
`
`By:
`
`
`On March 13, 2023, a PDF version
`of this document was filed with
`Clerk of the Court using the CM/ECF
`System for filing and for Transmittal
`Of a Notice of Electronic Filing to the
`Following CM/ECF registrants:
`
`Kevin Rapp, kevin.rapp@usdoj.gov
`Peter Kozinets, peter.kozinets@usdoj.gov
`Daniel Boyle, daniel.boyle2@usdoj.gov
`Margaret Perlmeter, margaret.perlmeter@usdoj.gov
`Andrew Stone, andrew.stone@usdoj.gov
`Austin Maxwell Berry, austin.berry2@usdoj.gov
`
`
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`2
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`1 2 3 4 5 6 7 8 9
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`1515
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`1616
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`1717
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`1818
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`1919
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`2020
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`2121
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`2222
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`2323
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`2424
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`2525
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`2626
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`2727
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`2828
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`
`
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