Case 2:18-cr-00422-DJH Document 1753 Filed 09/04/23 Page 1 of 2
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`Joy Malby Bertrand (AZ Bar No. 024181)
`JOY BERTRAND ESQ LLC
`P.O. Box 2734
`Scottsdale, Arizona 85252
`Telephone: (602)374-5321
`Facsimile: (480)361-4694
`joy.bertrand@gmail.com
`Attorney for Joye Vaught
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE DISTRICT OF ARIZONA
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`United States of America,
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` Plaintiff,
`vs.
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`Michael Lacey, et al.,
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` Defendants.
`
`
`NO. CR-18-00422-PHX-SMB
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`MOTION FOR LEAVE FOR
`DEFENDANT VAUGHT AND HER
`COUNSEL TO APPEAR BY PHONE AT
`SEPTEMBER 5, 2023 STATUS
`CONFERENCE
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`NOW COMES Defendant Joye Vaught to move this Court for leave for her and her lawyer
`to appear by phone at the September 5, 2023 wtatus conference in this matter. She further submits
`the following:
`This Court set the September 5, 2023 status conference over the Labor Day weekend, to
`address Defendant Scott Spear’s recent Covid diagnosis and its impact on the current jury trial. Ms
`Vaught had not planned to be in Court on September 5, 2023. Instead, she had planned to work a
`full day. If she must come to court, she will lose several hours of work and, therefore, income. Her
`ability to work during this trial is significantly curtailed, so asking Ms. Vaught to attend in person
`would be a considerable hardship.
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`DEFENDANT VAUGHT’S MOTION FOR LEAVE FOR HER AND HER COUNSEL TO APPEAR BY PHONE
`AT SEPTEMBER 5, 2023 STATUS CONFERENCE
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`Case 2:18-cr-00422-DJH Document 1753 Filed 09/04/23 Page 2 of 2
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`In an abundance of caution, Counsel asks this Court to allow her to appear by phone at the
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`September 5, 2023 hearing, as well. Counsel had planned to be returning from Nothern Arizona on
`September 5, 2023, returning to Phoenix in the evening. Additionally, while she has tested negative
`with at-home Covid tests, she does have some symptoms similar to those she had when she had
`Covid in June 2022: runny nose, constant headache, fatigue, and swelling in the joints of her hands.
`The joint swelling has only occurred for Counsel once before -- with the prior Covid infection.
`Since she was initially mis-diagnosed with “only” pneumonia the last time she had Covid, Counsel
`now is particularly cautious given this known exposure in close proximity to someone who has been
`diagnosed with and is symptomatic of Covid.
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`The Court will find attached a proposed Order.
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`RESPECTFULLY SUBMITTED this Fourth day of September, 2023,
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`By:
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`/s/ Joy Bertrand
`Joy Bertrand
`Attorney for Joye Vaught
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`On September 4, 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 Codefendant Counsel and
`CM/ECF registrants:
`
`Kevin Rapp, kevin.rapp@usdoj.gov
`Peter Kozinets, peter.kozinets@usdoj.gov
`Margaret Perlmeter, margaret.perlmeter@usdoj.gov
`Andrew Stone, andrew.stone@usdoj.gov
`Daniel Boyle, daniel.boyle2@usdoj.gov
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`DEFENDANT VAUGHT’S MOTION FOR LEAVE FOR HER AND HER COUNSEL TO APPEAR BY PHONE
`AT SEPTEMBER 5, 2023 STATUS CONFERENCE
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