Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

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AFFIDAVIT
I, Walter D. Hussey, of 94 Hunger ford Street, Hart: td, CT, being duly deposed
do solemnly swear to the following:
1. The undersigned. counsel was retained by Reynaldo rroyo to represent him in
United States of America v. Reynaldo Arroyo.
2, Mr. Arroyo was tried and convicted after a full trial.
3. Subsequent to his conviction and prior to his sentenc tg, Mr. Arroyo indicated to
the undersigned his intention to retain new counsel. t purposes of an appeal.
4. Undersigned counsel met personally with Mr. Arroy to discuss his pre—sentence
report prior to Mr. Arroyo’s sentencing.
5. At the aforementioned meeting, Mr. Arroyo was unc iivocal in his intention to
terminate the undersigned as his counsel. Furthertno , Mr. Arroyo indicated his
father had retained new counsel for purposes of an at eal. Mr. Arroyo was quite
candid and profane in discussing his opinion of th.e u tersigned.’s ability to
practice law.
6. On the day of Mr. An·oyo’s sentencin.g,.Mr. Arroyo t s again unequivocal in his
desire to terminate the `Lll'1dEI°Slg1‘l6d’S representation c Mr. Arroyo.
7. Mr. Ramon Arroyo, Reynaldo’s father, indicated to tl undersigned that new
counsel had been retained to represent his son for pur ises of an appeal.
Moreover, Mr. Arroyo requested certain documents, i rich were provided to him,
for the express purposes of an appeal.
8. At no point whatsoever after the verdict did Mr. Arro; indicate to the
undersigned a desire for the undersigned to effectuate 1 appeal. To the contrary,
Mr. Arroyo and his father were very clear in their stat intention of terminating
the undersigned as well as retaining new counsel for tl purpos f appeal.
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SWORN TO AND PERS ONALLY APPEARED BEF< LE ME, WALTER D.
HUSSEY, THIS 21ST DAY OF JULY, 2005.
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