Free Motion to Appoint Counsel re Reduction of Sentence Crack Cocaine Offense 18:3582 - District Court of Connecticut - Connecticut

Case 3:00-cr-00044-JCH Document 673 Filed 06/20/2008 Page 1 of 2
UNITED STATES DISTRICT COURT , “ `
DISTRICT OF CONNECTICUT 5 8
.. A q @11
UNITED STATES OF AMERICA NQl_1‘_3jQO`Qf Z4 (J CH)
vs. ‘ `
TODD DAVENDER JUNE 18, 2008
MOTION FOR REAPPOINTMEN T AS COUNSEL FOR THE
DEFENDANT, TODD DAVENDER
The defendant, TODD DAVENDER, by and through undersigned counsel, requests that
the Court reappoint counsel to represent Mr. Davender, in order to represent him for a
reduction of sentence crack cocaine pursuant to 18 U.S.C. §3582(C).
In making this motion, defendant asserts that undersigned counsel represented
defendant at the time of his original sentenci11g and is in the best position to represent at this
new stage in his case. Defendant has been incarcerated si11ce the time of his sentencing and is
otherwise without funds to pay for the services of counsel for this important motion.
WHEREF ORE, defendant respectfully moves this court to re—appoint undersigned
counsel to represent defendant in his pursuit of relief and reduction of his sentence pursuant to
18 U.S.C. §3582 and in light of Amendment 706 to the United States Sentencing Guidelines.
Defendant respectfully moves that his motion be granted.
RESPECTFULLY SUBMITTED,
DEFENDANT, TODD DAVENDER
I
E 7
BY r .
JONATHAN J. EINHORN, ESQ.
412 ORANGE Sg§EET
NEW HAVEN, NNECTICUT 06511
203·777·3777
FEDERAL BAR N O. ctoo163

Case 3:00-cr-00044-JCH Document 673 Filed 06/20/2008 Page 2 of 2
CERTIFICATION
I hereby certify that on June 18, 2008, a copy 0f the foregoing Motion was mailed, postage
prepaid t0 the following counsel of record:
Alina Reynolds, Esq.
Assistant U.S. Attorney
915 Lafayette Boulevard
Bridgeport, Connecticut 06604
Christine L. Sciarrino, Esq.
Assistant U.S. Attorney
157 Church Street
New Haven, Connecticut 06510 °·,_ rp
\ ‘ M ,.,., - "
JONATHAN J. EINHORN