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`Joy Bertrand, Esq.
`PO Box 2734
`Scottsdale, Arizona 85252-2734
`Telephone: 602-374-5321
`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 FOR MS.
`VAUGHT APPEAR BY PHONE OR
`VIDEOCONFERENCING AT
`AUGUST 18, 2023 STATUS
`CONFERENCE AND FRYE-
`COOPER HEARING
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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 to appear by phone or
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`video conferencing at the August 18, 2023 Status Conference and Frye-Cooper
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`hearing. As further grounds therefore, the Defendant submits the following:
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`This matter has two hearings set on the morning of August 18, 2023: a
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`status conference before Judge Humetewa and a Frye-Cooper hearing before
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`Judge Fine.
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`Case 2:18-cr-00422-DJH Document 1696 Filed 08/14/23 Page 2 of 3
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`Ms. Vaught lives in the Dallas, Texas area. Round-trip airfare to Phoenix
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`and lodging would cost approximately $1,000 before ground transportation – a
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`considerable expense for Ms. Vaught, who remains indigent.
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`The Court has allowed Ms. Vaught to appear at prior final pretrial
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`conferences and other substantive hearings by phone. Ms. Vaught can be
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`available by phone or videoconferencing for the August 18, 2023 hearings.
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`The Court will find attached a proposed Order.
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`RESPECTFULLY SUBMITTED on August 14, 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 1696 Filed 08/14/23 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`On August 14, 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 August
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`18, 2023 Status Conference and Frye-Cooper Hearing with the Arizona District
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`Court’s electronic filing system. Based on my training and experience with
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`electronic filing in the federal courts, it is my understanding that a copy of this
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`request will be electronically served upon opposing counsel and codefendant
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`counsel upon its submission to the Court.
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`Respectfully submitted this Eighteenth day of August, 2023.
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`s/Joy Bertrand
`Joy Bertrand
`Attorney for Defendant
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`Page 3
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