Free Ex Parte Motion - District Court of Arizona - Arizona

____ l’lECEl\/ED __ _____ _ :i:;;&*s
1 CROWE & SCOTT, P.A.
1100 E. Washington St. OCT 0 4 2005 l
2 Suite 200 g
Phoenix, Arizona 85034-1090 Cl—El°ll{__U S iifillfli E
3 Telephone: (602)252-2570 *7*5 l Elm ~“”l§i¥{,’·5g‘= #_
Facsimile: (602) 252-1939 .
4 Email: [email protected]
5 Tom Crowe (#002180)
Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA
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UNITED STATES OF AMERICA, 3 No. CR03-668-003-PHX-FJM
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Plaintifri EX-PARTE MOTION FOR
12 REAPPOINTMENT AS COUNSEL
v, PURSUANT TO CRIMINAL JUSTICE
I3 ACT
ANGEL GARCIA (3),
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Defendant.
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16 Defendant, Angel Garcia, by and through counsel undersigned, hereby moves for
17 reappointment as counsel for Defendant pursuant to the Criminal Justice Act, 18 U.S.C.
18 3600A, for the reason that issues have arisen regarding Defendant’s time computation and
19 anticipated release date as calculated by the Bureau of Prisons. Counsel for Defendant was
20 substituted for the Federal Defender on September 15, 2003 pursuant to CJ A. The Defendant
21 was sentenced to 37 months in the Bureau of Prisons on August 26, 2004 and is presently
22 being held in Florence, Colorado. It appears that the Defendant will be required to address
23 these post-sentencing issues with the Court through the filing of a motion.
l 24 Therefore, based upon Defendant’s indigent status, counsel moves for reappointment
25 pursuant the Criminal Justice Act for the foregoing purpose.
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Case 2:O3—cr—OO668-FJIVI Document 118 Filed 10/O4/2005 Page 1 of 2

1 Excludable delay under 18 U.S.C. § 3161(h)(8)(A) will not occur as a result of this
2 motion or of an order based thereon.
3 DATED this Lf-mday of October, 2005.
4 CROWE'& SC ,_, .A.
1 5
6 By _
7 Tom Crowe
1100 East Washington, Suite 200
8 Phoenix, Arizona 5034-1090
Attorneys for Defendant
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COPY of the f r oing hand
10 delivered this day of
October, 2005, to: .
11
Honorable Frederick J. Martone
12 Judge of the District Court
Sandra Day O’Connor U.S. Courthouse, Suite 526
13 401 W Washin§,ton Street SPC 62
Phoenix, AZ 8 003-2154
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Case 2:O3—cr—OO668-FJIVI Document 118 Filed 10/O4/2005 Page 2 of 2

Case 2:03-cr-00668-FJM

Document 118

Filed 10/04/2005

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Case 2:03-cr-00668-FJM

Document 118

Filed 10/04/2005

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