Free Motion to Appoint Counsel - District Court of Delaware - Delaware

Case 1:07-cr-00093-SLR

Document 15

Filed 08/13/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

vs. JONATHAN MCKINNEY Defendant

: : : Case No.: 1:07 CR 00093 SLR : : : :

ORDER AND NOW, this day of , 2007, upon Motion of Robert Sink, Esq.

and Paul M. Perlstein, Esq. it is hereby ORDERED and DECREED that Robert Sink, Esq, is admitted to the bar of this Court Pro Hac Vice and is appointed as co-counsel, pro bono, to assist in the representation of Defendant Jonathan McKinney. Mr. Sink shall not be entitled to remuneration or compensation for fees or costs pursuant to the Criminal Justice Act and Mr. Sink shall have no responsibility as counsel of record for the representation of Mt. McKinney.

By The Court:

____________________________ Sue L. Robinson, J.

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

vs. JONATHAN MCKINNEY Defendant

: : : : Case No.: 1:07-CR-00093-SLR : : :

MOTION FOR GTHE ADMISSION OF ROBERT SINK, ESQ. PRO HAC VICE AND APPOINTMENT AS CO-COUNSEL, PRO BONO, IN THE DEFENSE OF JONATHAN MCKINNEY TO THE HONORABLE SUE L. ROBINSON, JUDGE OF THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE: 1. The defendant, Jonathan McKinney, is charged with possession of child pornography (five [5] images). 2. Paul Perlstein, Esq., who is a member of the bar of this Court, was appointed to represent the Defendant under the Criminal Justice Act. 3. Robert Sink, Esq., who is an experienced trial lawyer, regularly assists Mr. Perstein in the representation of his clients. 4. Mr. Sink is a member in good standing of the Supreme Court of Pennsylvania, the United States District Court for the Eastern, Middle, and Western Districts of

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Pennsylvania, and the United States District Court for the District of Columbia. See Certification of Robert W. Sink attached as Exhibit A. 5. Mr. Sink understands that his representation of the Defendant as co-counsel is strictly on a pro bono basis. 6. Edmond Falgowski, Esq., Assistant U.S. Attorney, has no objection to the admission of Mr. Sink and his participation assisting Mr. Perlstein. WHEREFORE, it is respectfully requested that this Court grant this Motion for admission pro hac vice of Robert Sink.

Respectfully submitted, PERLSTEIN LAW

By: S/________________________ Paul M. Perlstein, Esq. Attorney for Defendant, Jonathan McKinney

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA,

vs. JONATHAN MCKINNEY Defendant

: : FILED UNDER SEAL : : Case No.: 1:07 CR 00093 SLR : : :

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE 1. I certify that I am eligible for admission to this Court. 2. I am admitted, practicing, and in good standing as a member of the Supreme Court of Pennsylvania, the United States District Court for the Eastern, Middle, and Western Districts of Pennsylvania, and the United States District Court for the District of Columbia. 3. I submit to the disciplinary jurisdiction of this Court for any alleged misconduct which occurs in the preparation or course of this action. 4. I certify I am generally familiar with this Court's Local Rules.

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5. In accordance with Standing Order for the District Court Fund effective 1/1/05, I further certify that the annual fee of $25.00 will be submitted to the Clerk's Office if so ordered by the Court. Respectfully submitted,

s/____________________ Robert W. Sink, Esq. Law Offices of Robert W. Sink 319 W. Front St. Media, PA 19063 610-566-0800 [email protected]