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

Case 3:00-cr-00158-AWT

Document 97

Filed 03/11/2008

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT __________________________________________ ) UNITED STATES OF AMERICA ) CRIMINAL ACTION NO. ) vs. ) 3:00cr158 (AWT) ) MIGUEL GUERRERO-CEDENO ) March 10, 2008 __________________________________________) MOTION OF DEFENDANT MIGUEL GUERRERO-CEDENO TO RE-APPOINT COUNSEL RE: REDUCTION OF SENTENCE CRACK COCAINE OFFENSE 18 U.S.C. §3582 Defendant Miguel Guerrero-Cedeno in the above-captioned criminal matter, through counsel, respectfully moves the Court hereby to re-appoint undersigned counsel to represent him at this time for purposes of defendant's pending motion to reduce his sentence pursuant to 18 U.S.C. §3582. 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.

Case 3:00-cr-00158-AWT

Document 97

Filed 03/11/2008

Page 2 of 3

THE DEFENDANT MIGUEL GUERRERO-CEDENO

By ______________________________ William M. Bloss Federal Bar No. ct01008 Koskoff Koskoff & Bieder 350 Fairfield Avenue Bridgeport, CT 06604 TEL: 203-336-4421 FAX: 203-368-3244 Email: [email protected]

Case 3:00-cr-00158-AWT

Document 97

Filed 03/11/2008

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, on this 10th day of March, 2008, to all counsel and pro se parties of record, as follows: H. Gordon Hall Assistant United States Attorney 157 Church Street New Haven, CT 06510 U.S. Probation Officer Bunita B. Keyes U.S. Probation Office 450 Main Street Hartford, CT 06103 _____________________________ William M. Bloss