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

Case 1:07-cr-00158-GMS

Document 30

Filed 06/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA v. JULIO GONZALEZ :: :: :: NUMBER 07-158 CRIMINAL ACTION

MOTION TO REQUEST COMPENSATION FOR TRANSLATION AND INTERPRETER SERVICES UP TO $3000

TO THE THE HONORABLE GREGORY M. SLEET, CHIEF JUDGE OF THE SAID COURT: Defendant JULIO GONZALEZ, by his attorney Mark S. Greenberg, Esquire, respectfully represents:

1.

Defendant has been charged with one count of Counterfeiting Federal Identification Documents to Obtain Employment, in violation of 18 U.S.C. § 1546 (Count I); two counts of Aggravated Identity Theft, in violation of 18 U.S.C. § 1028A (Counts II & IV); one count of Unlawful Possession and Use of a Social Security Card, in violation of 42 U.S.C. § 408(a)(7)( C) (Count III); and Unlawful Possession with Intent to Transfer Five or More Identification Documents, in violation of 18 U.S.C. § 1028(a)(3) (Count 5).

2.

Trial in this matter is scheduled for September 29, 2008.

3.

Counsel has met with the defendant and is able to communicated with him adequately in English. Nonetheless, the services of a Spanish interpreter may be needed in the event that the substance of the conversation becomes more technical in nature.

4.

The government has supplied the defendant with CDs of telephone conversations and faceto-face meetings between defendant and various confidential informants.

5.

These conversations are in Spanish. The government has supplied transcripts of these conversations which have been translated into English.

Case 1:07-cr-00158-GMS

Document 30

Filed 06/25/2008

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6.

Defendant may need to retain a translation service to confirm that these conversations have been accurately translated .

7.

Counsel for defendant believes that the compensation for any translation and interpretive services will exceed $500.

8.

Accordingly, defendant requests this Court to authorize up to $3000 for translation and interpreter services. In this way, the defendant does not need to make repeated requests of this Court for additional funds for these services. Should the defendant need additional funds, he will petition the Court for them.

9.

The government will not be prejudiced as a vigorous and thorough defense on behalf of defendant will uphold the integrity of the American adversarial system of justice.

WHEREFORE, defendant respectfully requests this Court to enter an Order authorizing the reimbursement of interpreter and translation services up to $3,000.

/s/ ___________________________________ MARK S. GREENBERG, ESQUIRE 1429 Walnut Street, 13th Floor Philadelphia, PA 19102 215-735-5900

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Case 1:07-cr-00158-GMS

Document 30

Filed 06/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA v. JULIO GONZALEZ :: :: :: NUMBER 07-158 CRIMINAL ACTION

ORDER AND NOW, this Day of 2008, it is ORDERED AND DECREED that

defendant's Motion to Request Compensation for Translation and Interpreter Services up to $3000 is GRANTED.

BY THE COURT:

________________________

Case 1:07-cr-00158-GMS

Document 30

Filed 06/25/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA v. JULIO GONZALEZ :: :: :: NUMBER 07-158 CRIMINAL ACTION

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct of the foregoing response was served upon AUSA Keith Rosen, 1007 Orange Street, Wilmington, Delaware on the date below via electronic filing.

/s/ ___________________________________ MARK S. GREENBERG, ESQUIRE Attorney for Defendant

DATED: June 25, 2008