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

Case 1:08-cr-00037-JJF

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Filed 06/02/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. IRA BLAND, Defendant. : : : : : : : : :

Criminal Action No. 08-37-JJF

MOTION FOR AUTHORIZATION TO INCUR EXPENSES FOR INVESTIGATIVE SERVICES Christopher S. Koyste, on behalf of Ira Bland, hereby moves the Court for authorization to incur expenses for investigative services on behalf of Defendant in the above captioned matter. In support of this motion, it is further represented as follows: 1. Defendant has been indicted for felony possession of a firearm in and affecting interstate commerce. Defendant has been determined to be indigent and eligible for Court appointed representation. 2. The undersigned has determined in his professional judgment that the services of an investigator are needed in this case to investigate any potential suppression issues and to prepare for hearings in this action. Counsel has already had discussions with private investigator Tom Monahan1

Tom Monahan of Monahan, Monahan & Golt Investigations is a retired Wilmington Police Officer and currently is the Director of Public Safety for Winterthur and is licensed by the State of Delaware to be a private investigator. His business address is 8 East 13 Street, Wilmington, Delaware 19801.

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Case 1:08-cr-00037-JJF

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in relation to this case. Defendant requests approval to retain Mr. Monahan to provide investigative services in this case at a rate of $60.00 an hour and a total cost that will not exceed $1,200.00. WHEREFORE, Defendant requests that the Court approve the expenditure of up to $1,200.00 for investigative services to be paid by the District Court for the District of Delaware.

____________________________ Christopher S. Koyste (# 3107) 709 Brandywine Boulevard Bellefonte, DE 19809 302-762-5195 Attorney for Defendant Bland

Case 1:08-cr-00037-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. IRA BLAND, Defendant. : : : : : : : : :

Criminal Action No.08-37-JJF

ORDER Having considered Defendant's Motion for Authorization to Incur Expenses for Investigative Services, IT IS HEREBY ORDERED this day of _____________, 2008, that Defendant's

Motion is GRANTED and that the Firm of Monahan, Monahan and Golt is authorized to provide investigative services at the rate of $60.00 an hour, up to a total of $1,200.00 in this case.

Judge Joseph J. Farnan, Jr.

Case 1:08-cr-00037-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. IRA BLAND, Defendant. : : : : : : : : :

Criminal Action No. 08-37-JJF

CERTIFICATE OF SERVICE Undersigned Counsel certifies that the attached filing of Ira Bland is available for public viewing and downloading and was electronically delivered on June 2, 2008 to:

Shawn Martyniak, Esquire Assistant United States Attorney United States Attorney's Office 1007 Orange Street, Suite 700 Wilmington, Delaware 19801

/s/ Christopher S. Koyste Christopher S. Koyste, Esquire 709 Brandywine Boulevard Bellefonte, Delaware 19809 (302) 762-5195 Email: [email protected] Attorney for Ira Bland