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

Case 3:03-cr-00198-RNC

Document 1084

Filed 04/21/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

------------------------------------------------------x UNITED STATES OF AMERICA, Plaintiff VS. CRIMINAL ACTION NO. 3:03CR-198 (RNC)

ANTONIO (RAMON) MARRERO, Defendant ------------------------------------------------------x

APRIL 20, 2006

APPLICATION FOR APPROVAL TO INCUR EXPENSES FOR EXPERT SERVICES

Defendant Antonio (Ramon) Marrero, in the above-captioned criminal matter, respectfully applies to the Court hereby, through counsel, pursuant to the provisions of the Criminal Justice Act, for the Court's approval of certain expenses necessary to the representation of the defendant in this case. The expenses for which approval is requested involve the services already provided by a Spanish language interpreter during various conferences conducted with the defendant at the Donald W. Wyatt Detention Facility in Central Falls, Rhode Island. As the Court is aware, defendant neither speaks, nor reads English. As a result, in order to confer with defendant on the many dates when that occurred, the interpreter counsel uses for every Spanish-speaking defendant held at Wyatt, Ms. Inge Gomez-Michel, was used for this purpose. Ms. Gomez-Michel has been found qualified by the District Court in

Case 3:03-cr-00198-RNC

Document 1084

Filed 04/21/2006

Page 2 of 3

the past and her services in this matter were essential to the effective representation of Mr. Marrero. Wherefore, counsel for defendant respectfully applies to the Court to approve the vouchers submitted by Ms. Gomez-Michel and to pay them in accordance with the terms and requirements of the Criminal Justice Act. To the extent that the Court needs a dollar figure for purposes of this application, counsel requests that the sum of $2,500.00 be authorized in this instance to cover any outstanding vouchers that might exist for Ms. Gomez-Michel's services. Undersigned counsel asserts that he does not anticipate any additional requests for these kinds of services in this case in the future. WHEREFORE, in consideration of the foregoing, defendant requests that his application be granted.

DEFENDANT, ANTONIO MARRERO

By: ___________________________ John T. Walkley 450 Monroe Turnpike, Suite 101 Monroe, Connecticut 06468 Telephone (203) 261-1911 Facsimile (203) 268-1433 Email Address: [email protected] Fed. Bar No. ct04341

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Case 3:03-cr-00198-RNC

Document 1084

Filed 04/21/2006

Page 3 of 3

CERTIFICATION It is certified hereby that a copy of the foregoing was dispatched via first class mail, postage prepaid, this 20th day of April, 2006, to:

Gordon Hall, Esq. Asst. United States Attorney P.O. Box 1824 New Haven, Connecticut 06508-1824

____________________________ John T. Walkley

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