DEFENDANT’S MOTION AND MEMORANDUM IN SUPPORT OF ADDITIONAL AUTHORIZATION FOR SENTENCING INVESTIGATION
COMES NOW the Defendant, Ulriste Tulin, by counsel, and submits his motion and amended budget proposal for additional authorization for sentencing investigation in this matter pursuant to the Criminal Justice Act (“the Act”). In support of such motion, the following is submitted:
1. The defendant was charged with Conspiracy to Commit Hostage Taking, 18 U.S.C. § 1203, two counts of Aiding and Abetting of Hostage Taking, 18 U.S.C. §§ 1203, 2, and Using a Firearm during a Crime of Violence and Aiding and Abetting, 18 U.S.C. § 924.
2. The defendant was found guilty by a jury and is pending sentencing, where he faces a life sentence.
3. To …show more content…
Investigator/mitigation (to be determined) - $125 (if Court transfers previously authorized funds) or in the alternative 25 hours at $100/hour for a total of $2500
10. The projected costs/fee are counsel’s best good faith estimates based counsel’s experience and counsel’s consultation with the service providers and the Circuit Case Budgeting Attorney.
11. Counsel has endeavored to keep costs down whenever possible, taking into account their ethical obligations to provide adequate representation and of budgetary constraints under the Criminal Justice Act.
12. Counsel respectfully requests that the Court allows authorize the additional funds for sentencing investigation.
13. If the Court requires additional information or clarification, counsel is ready to respond to any inquiries.
14. The trial and sentencing strategies of the defendant’s counsel are privileged, and therefore, this request is made ex parte.
WHEREFORE, defendant, Ulriste Tulin, through counsel, respectfully requests that Honorable Court approve the additional authorization for sentencing investigation in this matter pursuant to the Criminal Justice Act (“the Act”) and grant leave to proposed necessary amendments should they become necessary by a change in circumstances as this matter
COMES NOW the Defendant, Ulriste Tulin, by counsel, and submits his motion and amended budget proposal for additional authorization for sentencing investigation in this matter pursuant to the Criminal Justice Act (“the Act”). In support of such motion, the following is submitted:
1. The defendant was charged with Conspiracy to Commit Hostage Taking, 18 U.S.C. § 1203, two counts of Aiding and Abetting of Hostage Taking, 18 U.S.C. §§ 1203, 2, and Using a Firearm during a Crime of Violence and Aiding and Abetting, 18 U.S.C. § 924.
2. The defendant was found guilty by a jury and is pending sentencing, where he faces a life sentence.
3. To …show more content…
Investigator/mitigation (to be determined) - $125 (if Court transfers previously authorized funds) or in the alternative 25 hours at $100/hour for a total of $2500
10. The projected costs/fee are counsel’s best good faith estimates based counsel’s experience and counsel’s consultation with the service providers and the Circuit Case Budgeting Attorney.
11. Counsel has endeavored to keep costs down whenever possible, taking into account their ethical obligations to provide adequate representation and of budgetary constraints under the Criminal Justice Act.
12. Counsel respectfully requests that the Court allows authorize the additional funds for sentencing investigation.
13. If the Court requires additional information or clarification, counsel is ready to respond to any inquiries.
14. The trial and sentencing strategies of the defendant’s counsel are privileged, and therefore, this request is made ex parte.
WHEREFORE, defendant, Ulriste Tulin, through counsel, respectfully requests that Honorable Court approve the additional authorization for sentencing investigation in this matter pursuant to the Criminal Justice Act (“the Act”) and grant leave to proposed necessary amendments should they become necessary by a change in circumstances as this matter