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

Case 3:08-cr-02430-BTM

Document 43

Filed 08/18/2008

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KAREN STEVENS Attorney at Law California Bar No. 110009 105 W. "F" Street San Diego, California 92101 Telephone No. (619) 239-8553 Facsimile No. (619) 239-0056 Attorney for Defendant: GERARDO SALTO-ROCHA

UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 10 11 vs. 12 GERARDO SALTO-ROCHA, 13 Defendant. 14 15 16 COMES NOW DEFENDANT, GERARDO SALTO-ROCHA, by and through his 17 counsel, 18 additional funds in the above-entitled matter, for the following reasons: 19 1. Counsel for Defendant was appointed to this case on or about July 10, 2008; 20 2. To date, counsel has received approximately 260 of pages of discovery, as well as the 21 video-taped, post-arrest interviews of eight individuals; an additional taped interview is anticipated. 22 Counselor's interpreter has met with Defendant (with and without counsel's presence) on numerous 23 occasions, at the M.C.C; she has also reviewed the C.D. Containing the above-referenced video24 taped interviews, and has interpreted and summarized those interviews. To date, attorney's 25 interpreter expenses are already at the amount authorized, and perhaps a few hours beyond; 26 3. This case is a potential "death penalty"; which counsel will require the expenditure of 27 many more hours by counsel's interpreter. 28 4. Therefore, counsel submits the interpreter will require at a minimum, another twenty-five Karen M. Stevens, and hereby requests this Court to approve of the expenditure of UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) CASE NO. 08CR2430-BTM DEFENDANT'S EX PARTE REQUEST FOR EXTRAORDINARY EXPENSES; ORDER THEREON

Case 3:08-cr-02430-BTM

Document 43

Filed 08/18/2008

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to thirty hours to continue assisting counsel in this matter. Wherefore, counsel requests this Court Order Extraordinary expenses for interpreter Sylvia Castro, not to exceed an additional thirty (30) hours.

Dated: August 18, 2008

Respectfully submitted,

/S/ Karen M. Stevens Karen M. Stevens Attorney for Defendant GERARDO SALTO-ROCHA

ORDER

GOOD CAUSE APPEARING, it is hereby Ordered that Defense counsel's interpreter,

14 Sylvia Castro, is authorized to submit additional hours for her time interpreting in the instant case, not 15 to exceed an additional thirty (30) hours. 16 17 18 19 20 21 22 23 24 25 26 27 28 -2IT IS SO ORDERED. Date: HON. BARRY TED MOSKOWITZ