Free Motion to Appoint Counsel - District Court of Arizona - Arizona

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Gail Gianasi Natale Arizona State Bar #010389 817 North Second Street Phoenix, AZ 85004 602/258-1778 Attorney for Defendant UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Mr. Freeman continues to represent Ms. Reed only on her 28 U.S.C. § Petition for Habeas Corpus.
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UNITED STATES OF AMERICA, Plaintiff, v. CAROLYN REED, Defendant.

No. CR 03-421-PHX-SMM MOTION FOR APPOINTMENT TO REPRESENT DEFENDANT FOR POSSIBLE SENTENCE REDUCTION

COMES NOW Defendant CAROLYN ANN REED, by and through counsel undersigned, and respectfully moves this Court for an order appointing the undersigned to represent her for a possible sentence reduction pursuant to the retroactive amendments to the crack cocaine guidelines. The Federal Public Defender (FPD) cannot represent Ms. Reed because it represented one of her co-defendants. At

sentencing Ms. Reed was represented by retained counsel, Michael L. Freeman 1, who no longer is a member of the CJA Panel. The FPD has asked the undersigned to represent Ms. Reed for possible resentencing issues. been submitted to this Court. Her financial affidavit has

Case 2:03-cr-00421-SMM

Document 638

Filed 04/21/2008

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Ms. Reed asks that the appointment of the undersigned be nunc pro tunc February 25, 2008, the date the FPD asked the undersigned to represent the Defendant. RESPECTFULLY SUBMITTED this 21st day of April, 2008. Gail Gianasi Natale /s Gail Gianasi Natale Attorney for Defendant ORIGINAL of the foregoing efiled this 21st day of April, 2008 to: U.S. District Court District of Arizona (Phoenix Division) COPIES of the foregoing mailed this 21st day of April, 2008, to: HONORABLE STEPHEN M. McNAMEE United States District Court Sandra Day O'Connor U.S. Courthouse, Suite 625 401 W. Washington Street, SPC 60 Phoenix, AZ 85003-2158 Ms. Carolyn Reed #80640-008 FCI--Victorville Medium II Satellite Camp P.O. Box 5100 Adelanto CA 92301 Informational copies emailed to: Deborah Williams [email protected] Michael Freeman [email protected] s/Anita Jundy

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Case 2:03-cr-00421-SMM

Document 638

Filed 04/21/2008

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