Free Notice of Attorney Appearance - Defendant - District Court of Arizona - Arizona

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LAW OFFICE OF NEIL C. LABARGE
NEIL C. LABARGE State Bar No. 13920 11 W . Jefferson St., #2 Phoenix, AZ 85003 (602) 252-4090 FAX (602) 252-2111 Attorney for Defendant Maldonado-Perez

IN THE UNITED STATES DISTRICT COURT 7 DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comes now attorney Neil C. LaBarge, and respectfully requests that the court appoint him to represent Defendant under the Criminal Justice Act ("Act") for all further proceedings through Re-Sentencing. Defense counsel requests that the court grant the appointment nunc pro tunc to February 22, 2006. This request is based on the following: Defendant. v. BESY A. MALDONADO-PEREZ, U.S.A., Plaintiff, No. CR03-1064-PHX-SMM NOTICE OF APPEARANCE, AND REQUEST FOR NUNC PRO TUNC APPOINTMENT UNDER THE CRIMINAL JUSTICE ACT

1) Undersigned counsel represented defendant at the trial in this matter and is therefore more familiar with the facts than any other CJA panel attorney. Defendant was appointed an attorney under the Act on appeal, having filed the required affidavit of indigency. Attorney Michele Moretti represented counsel on the appeal. Attorney Moretti does not wish to represent Defendant before the trial court on the Re-Sentencing. 2) Defendant has been detained since arrest, and has been serving the prison sentence imposed by the court at the original sentencing. Therefore, her financial conditions have not changed since the beginning of the appeal, and she is still indigent. 3) Undersigned counsel began substantive work on this matter on February 22, 2006, when he began discussing issues with the defendant and her appellate attorney, Ms. Moretti. Case 2:03-cr-01064-SMM Document 109 Filed 03/07/2006 Page 1 of 2

1 2 3 LAW OFFICE OF NEIL C. LABARGE 4 S/Neil C. LaBarge 5 ________________________________ 6 NEIL C. LABARGE 7 8 9 Original filed with the following via ECF this date: March 7, 2006. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2Filed 03/07/2006 Clerk of the Court 401 W. Washington St. Phoenix, AZ 85003 Copies e-mailed to the following on this date: March 7, 2006. Honorable Stephen M. McNamee [email protected] Copies mailed/faxed to the following on this date: March 7, 2006. Honorable Stephen M. McNamee 401 W. Washington St. Phoenix, AZ 85003 Gary Restaino, AUSA 40 N. Central Ave., #1200 Phoenix, AZ 85004 Respectfully submitted this date: March 7, 2006.

Case 2:03-cr-01064-SMM

Document 109

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