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

Case 3:03-cr-00277-PCD

Document 40

Filed 06/13/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA v. SUSAN GODDING : : : June 7, 2005 CRIMINAL NO. 3-03-cr-277

MOTION FOR APPOINTMENT OF COUNSEL PURSUANT TO THE CRIMINAL JUSTICE ACT The defendant, Susan Godding, respectfully moves the Court to appoint her attorney, Charles F. Willson, as her counsel pursuant to the Criminal Justice Act ("CJA"). In support of this Motion, the defendant states the following grounds: 1) The defendant cannot afford to pay Nevins & Nevins LLP to continue to

represent her. The defendant will submit a financial affidavit for the Court's consideration at the June 15, 2005 hearing. 2) Attorney Willson was recently added to the CJA Panel for this District,

and has an application pending to serve on the CJA Panel for the U.S. Court of Appeals for the Second Circuit. 3) Attorney Willson's representation of the defendant dates back to May

2004 and includes representing the defendant during the appeal by the United States to the Court of Appeals for the Second Circuit.

Case 3:03-cr-00277-PCD

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Filed 06/13/2005

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WHEREFORE, the defendant respectfully requests that the Court appoint Attorney Willson as her attorney pursuant to the Criminal Justice Act, as of the date of this Motion. Respectfully submitted, DEFENDANT, SUSAN GODDING

Dated: June 7, 2005

By Charles F. Willson (ct24129) NEVINS & NEVINS LLP Her Attorneys 102 Connecticut Boulevard P. O. Box 280658 East Hartford, CT 06128 (860) 289-4455 fax: (860) 289-8968 [email protected]

Case 3:03-cr-00277-PCD

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Filed 06/13/2005

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CERTIFICATION This is to certify that a copy of the foregoing has been sent via U.S. mail, postage prepaid, on June 7, 2005, to all counsel and parties of record as follows: COUNSEL FOR THE GOVERNMENT: John Danaher III, Esq. Assistant United States Attorney 450 Main Street, Room 328 Hartford, CT 06103 COURTESY COPY TO PROBATION: Bunita Keyes Office of Adult Probation 450 Main Street, Room 735 Hartford, CT 06103-3002

Charles F. Willson