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

Case 3:02-cr-00300-AVC

Document 91

Filed 04/28/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. HERIBERTO BATIZ APRIL 23, 2008 NO. 3:02cr300 (AVC)

MOTION FOR REAPPOINTMENT AS COUNSEL FOR THE DEFENDANT, HERIBERTO BATIZ The defendant, Heriberto Batiz, by and through undersigned counsel, requests that the Court reappoint counsel to represent Mr. Batiz, 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 sentencing and is in the best position to represent at this new stage in his case. Defendant has been incarcerated since the time of his sentencing and is otherwise without funds to pay for the services of counsel for this important motion. WHEREFORE, 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, HERIBERTO BATIZ BY ______________________ JONATHAN J. EINHORN, ESQ. 412 ORANGE STREET NEW HAVEN, CONNECTICUT 06511 203-777-3777 FEDERAL BAR NO. ct00163

Case 3:02-cr-00300-AVC

Document 91

Filed 04/28/2008

Page 2 of 2

CERTIFICATION I hereby certify that on April 23, 2008, a copy of the foregoing Motion was mailed, postage prepaid to the following counsel of record:

Henry K. Kopel U.S. Attorney's Office 157 Church St., PO Box 1824 23rd Floor New Haven, CT 06510 John A. Danaher, III U.S. Attorney's Office 450 Main St. Room 328 Hartford, CT 06103
Keith Barry U.S. Probation Office 915 Lafayette Boulevard Bridgeport, Connecticut 06604

___________________________ JONATHAN J. EINHORN