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`Joy Bertrand, Esq.
`PO Box 2734
`Scottsdale, Arizona 85252-2734
`Telephone: 480-656-3919
`Fax: 480-361-4694
`joyous@mailbag.com
`www.joybertrandlaw.com
`Arizona State Bar No. 024181
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`ATTORNEY FOR: DEFENDANT
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF ARIZONA
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`United States of America,
`Plaintiff,
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` CR-2018-0422-SMB
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`MOTION FOR LEAVE TO APPEAR
`BY PHONE AT MARCH 20, 2023
`HEARING (EXPEDITED REVIEW
`REQUESTED)
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`Joye Vaught,
`Defendant.
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`v.
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`NOW COMES the Defendant, Joye Vaught, by and through her counsel of
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`record, Joy Bertrand, to ask this Court for leave for her counsel to appear by
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`phone at the March 20, 2023 Hearing set in this matter. As further grounds
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`therefore, the Defendant submits the following:
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`One of Undersigned Counsel’s family has entered the active dying stage of
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`hospice care and is not expected to live through the weekend. To allow Counsel
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`to be present for her family, she asks for leave to appear by phone at the March
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`20, 2023 hearing in this matter.
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`Case 2:18-cr-00422-DJH Document 1543 Filed 03/18/23 Page 2 of 3
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`The Court will find attached a proposed Order.
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`RESPECTFULLY SUBMITTED on March 16, 2023.
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`s/Joy Bertrand
`Joy Bertrand
`Attorney for Defendant
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`Page 2
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`Case 2:18-cr-00422-DJH Document 1543 Filed 03/18/23 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`On March 18, 2023, I, Joy Bertrand, attorney for the Defendant, Joye
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`Vaught, filed the Defendant’s Motion for Leave to Appear by Phone at March 20,
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`2023 Hearing with the Arizona District Court’s electronic filing system. Based on
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`my training and experience with electronic filing in the federal courts, it is my
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`understanding that a copy of this request will be electronically served upon
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`opposing counsel and codefendant counsel upon its submission to the Court.
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`Respectfully submitted this Eighteenth day of March, 2023.
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`s/Joy Bertrand
`Joy Bertrand
`Attorney for Defendant
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`Page 3
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