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					 1   DIANE J. HUMETEW A
     United States Attorney
     District of Arizona
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     PETER SEXTON
 3   Assistant U.S. Attorney
     Arizona State Bar No. 011089
     peter.sexton@usdoj.gov
 4   Two Renaissance Square
     40 N. Central Avenue, Suite 1200
     Phoenix, Arizona 85004-4408
 5   Telephone: (602) 514-7500

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                                        UNITED STATES DISTRICT COURT
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                                             DISTRICT OF ARIZONA
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 9    United States of America,
                                                                 CR-02-993 PHX-FJM
10                              Plaintiff,
11                     v.                               UNITED STATES’ PRELIMINARY
                                                            RESPONSE TO ROBERT
12    Kwikmed, et. al,                                     JOHNSON’S AND GROUPE
                                                          ANGELIL INTERNATIONAL
13                                                       HOLDSINGS, S.A.’S RULE 54(b)
                                Defendants.             MOTION FOR CERTIFICATION OF
14                                                        JUDGMENT AND RULE 58(d)
                                                            MOTION FOR ENTRY OF
15                                                          SEPARATE JUDGMENT
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             Third parties Robert Johnson and Groupe Angelil International Holdings have filed a
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     pleading entitled “Robert Johnson’s and Groupe Angelil International Holdings, S.A.’s Rule
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     54(b) Motion for Certification of Judgment and Rule 58(d) Motion for Entry of Separate
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     Judgment” ( hereafter “Certification Motion”) (CR 268). This was filed by defendant in reaction
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     to the Court’s December 19, 2007 Order (CR 267), which was a consolidated ruling addressing
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     several pending motions.
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             The forfeiture aspect of this matter was being handled by AUSA Lisa Roberts, who
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     worked for many years in the forfeiture unit of the United States Attorney’s Office. She recently
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     took a position in Washington, D.C. with the Office of International Affairs. The only other
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     forfeiture lawyer in the Phoenix office is Reid Pixler, who is finishing up a two year assignment
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     Case 2:02-cr-00993-FJM              Document 269   Filed 01/23/2008   Page 1 of 3
 1   in Iraq. Thus, the United States Attorney’s Office in Phoenix is without any forfeiture lawyers
 2   at this time.
 3          As I am the criminal AUSA who prosecuted the criminal matter, it is unclear to me
 4   whether the Court needs a response from the government to the Certification Motion recently
 5   filed. If the Court believes a response is needed from the government, could the Court direct the
 6   government to respond in a separate order or other communication. If a response is needed, I
 7   will attempt to find a lawyer with expertise in this area who can assist me in responding to the
 8   Certification Motion.
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            Respectfully submitted this 23 rd day of January, 2008.
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11                                                      DIANE J. HUMETEWA
                                                        United States Attorney
12                                                      District of Arizona
13                                                      S/ Peter Sexton
14                                                      PETER SEXTON
                                                        Assistant U.S. Attorney
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     Case 2:02-cr-00993-FJM       Document 269          Filed 01/23/2008   Page 2 of 3
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     I hereby certify that on January 23, 2008,
     I electronically transmitted the attached
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     document to the Clerk’s Office using the
     CM /ECF system for filing and
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     transmittal of a Notice of Electronic Filing
     to the following CM/ECF registrants:
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     Alexander Poulos
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     Tiffany & Bosco
     2525 East Camelback Rd.
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     Phoenix, AZ 85016
     Counsel to Robert Johnson and Groupe Angelil
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     Larry Hammond                                   Thomas Hoidal
     Maureen Beyers                                  Hoidal and Hannah, PLC
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     Osborn Maledon, PA                              111 W est Monroe, Suite 1210
     2929 N. Central, Suite 2100                     Phoenix, AZ 85003-1732
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     P.O. Box 36379                                  Counsel for Janice Gamblin
     Phoenix, AZ 85067-6379
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     Counsel for Ronald W anchuk
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     Tyrone Mitchell, Esq.                           Adrian P. Fontes, Esq.
     1700 North Seventh Street, Suite 3              111 W est Monroe Street, Suite 425
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     Phoenix, AZ 85006                               Phoenix, AZ 85003
     Counsel for Keith Salvato                       Counsel for Kim Salvato
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         S/ Peter Sexton
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     Case 2:02-cr-00993-FJM                Document 269       Filed 01/23/2008        Page 3 of 3

				
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