Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

__ , . .... ;2--_--_....sM.“-..-..—-...;...—;-—.L -.11 ———————-—-·——;·——-———-·—-——
[ C se 3:03-cr—OO198-RNC Document 1013 Filed O3/24/2006 Page 1 of 4 I
1 » — 0 any
1
UNITED STAT 1 ' ll ISTRICT COURT , n I _ `
f DISTRICT ONNECTICUT I
y UNITED STATES OF AMERICA R :
1 VS. p : I
1 JOEL ROMAN N : MARCH 22, 2006
MOTION FOR REAP ll NTMENT AS CJA COUNSEL
Pursuant to 18 U.S.C. Sec. 3006 I! efendant JOEL ROMAN, by and through
I1
his undersigned counsel, hereby reques L `· is Honorable court to re-appoint Attorney
. . I1 1
Margaret P. Levy under the Criminal 1 t ce Act to represent him in a re-sentencing
matter ancillary to the above captioned lter. He represents in support of said
motion:
1) On July 11, 2003, the Defend mwas arrested by Connecticut state
. 1 1
authorities on drug charges underlying h 1ab0ve captioned matter. A
I
2) On October 9, 2003, he was s p nced to serve a term of 42 months on the I
Connecticut charges.
3) Three weeks later, on Oetobe » 1 2003, he was arrested on the federal
Indictment; undersigned counsel was a •}• 11 ` ted as CJA counsel shortly thereafter.
4) Undersigned counsel represe i = •\ the Defendant in state court for the
. 1 1I
limited purpose of vaeating his state sen ·p· 1 e so he could be federally sentenced and
then re-sentenced concurrently in state Jn i . 1
1 I

1 1 .
1 1
I
1
. .',” [Q; .”,” .”,' [L'; [L; .”,' [;”;`; .”,' [Qi; .”,'

. .”,” [Q; .',” [Q; .',' [Q; [`.[;?;;; [`.[;Z; .”,” [L; [L;

_ _ C se 3:03-cr—00198?:ll§|C Document 1 • Filed 03/24/2006 Page 2 of 4 .
. _222 U i
5) On June 23, 2004, his federa s p tence was vacated and he was "remanded I
to Federal custody."
6) On December 16, 2004, the It- widant was sentenced to a term 0f 96
, months minus 17 months (representing ll it for the time already served in state
l custody from 7/l0/03 to 12/16/04), resul l in a federal sentence of 79 months I
to serve.
7) Unbeknownst to undersigne c l nsel, the Defendant, the state court
prosecutor, the government, and the fe · ( and state courts, vacating the state
sentence had not put the Defendant in f ia ml custody; instead, he remained in state
custody. U
8) As a result of the above misu d standing, the Defendant completed the
Ii t
balance of his state sentence before bein pansferred to federal custody.
9) He is now serving his federal hence consecutively to the balance of his }
state sentence,
10) Despite the best efforts of co L, the Defendant has not yet received l
credit for the additional time spent in st lt ustody.
Il) The Defendant is currently i H eral custody at the Medium security
prison of the Coleman Correctional Co in Coleman, Florida.
I .
12) He has no assets with which p tain private counsel. (FINANCIAL *
AFFIDAVIT, CJA-23, filed under seal yh 14, 2006). I
i 5
H ii i

. ll "";"”""'“"""""““_—`”"""”““_|
C se 3:03-cr—00198-RNC Document 1 • Filed 03/24/2006 Page 3 of 4 l
‘ “ l i lt-)
WHEREFORE, the Defendant respect IT requests that undersigned counsel be re-
appointed t0 resolve the issues related ¤ s sentence.
s l p
[ DEFENDANT, JOEL ROMAN
l
l BY
l , MA A T P. LEVY
Federal rN0. ct00045
K His Attorney
p 21 Oak Street
Hartford, CT 06106-8001
(860) 52549119
l
l li
l l
ll
l l
Y 3
‘ l
l l i
l a
l M
N l
l
l

ll
li
ll
l ll
l l
l l »
H x

l C e 3:03-cr—OO198?l§lC Document 1 • : Filed 03/24/2006 Page 4 of 4
. '° ' l \)
CERTIFI TION
THIS IS TO CERTIFY that a c u`] of the foregoing was mailed this day,
postage pre-paid, or was hand-delivere l clothe following;
A l
Hon. Robert N. Chatigny l
United States District Court l lp
F 450 Main Street
{ Hartford, CT 06103 r R
1 AUSA H. Gordon Hall
157 Church Street — 23d floor pi
New Haven, CT 06510
Joel Roman
Reg. N0. 15336-014
Federal Correctional Complex l
Coleman - Medium l
P.O. Box 1032
Coleman, FL 33521-1032
I @@,.41%,
R MA GA T P. LEVY i
l i
l
l M
l l_
l
0 M
l l
H ll