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

Case 3:00-cr-00263-JCH

Document 1786

Filed 03/17/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT __________________________________________ : UNITED STATES OF AMERICA : : CRIM. NO. 3:00CR263 (JCH) VS. : : TODD SUMMERVILLE : March 17, 2006 __________________________________________: MOTION TO APPOINT COUNSEL The defendant in the above-captioned matter hereby moves that the undersigned be appointed as counsel for the defendant for the purposes of proceedings in this Court. In support of this motion, defendant represents that he was represented by Sarah Chambers of the Federal Public Defenders office. The undersigned was appointed by the Court of Appeals for the purpose of his appeal under the terms 18 U.S.C. § 3006A. The Court of Appeals ordered the case remanded for the purpose of determining whether this Court would have ordered a non-trivially different sentence had the Guidelines been advisory. It would seem reasonable, under the circumstances, to continue the representation started in the Court of Appeals in this case. On information and belief defendant is still qualified for appointed counsel, as he is now incarcerated pursuant to the Court's sentence, and has been since 2002. THE DEFENDANT By________________________________ William M. Bloss, No. ct01008 Koskoff Koskoff & Bieder, P.C. 350 Fairfield Avenue

Case 3:00-cr-00263-JCH

Document 1786

Filed 03/17/2006

Page 2 of 3

Bridgeport, CT 06604 TEL: 203-336-4421 FAX: 203-368-3244 email: [email protected]

Case 3:00-cr-00263-JCH

Document 1786

Filed 03/17/2006

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing has been mailed, postage prepaid, on this 17th day of March 2006, to all counsel and pro se parties of record, as follows: Paul Murphy, Esquire Assistant U.S. Attorney 915 Lafayette Blvd. Bridgeport, CT 06604 ________________________________ William M. Bloss