Cygnus Systems, Inc. v. Microsoft Corporation, et al

Filing 801

Cygnus Systems, Inc. v. Microsoft Corporation, et al

Doc. 801

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Law Office of Peter Hormel, pc
4711 N. 1st Ave. Tucson, AZ 85718 [phone] Fax [phone] Peter Hormel Arizona Bar No. 015808 Attorney for Defendant UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA
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UNITED STATES OF AMERICA,
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CR-07-1120-TUC-JMR (GEE)

Plaintiff,
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vs.
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AMENDED MOTION FOR APPROVAL OF FUNDS

13. CARMELO AROZ-ARAIZA,
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Defendant.
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COMES NOW, Carmelo Aroz-Araiza, by and through counsel undersigned,
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and hereby moves the court to approve funds in excess of $500 for the purposes of trial preparation. Counsel had previously contracted with Sandra Frady to prepare transcriptions and translations of the Spanish-language interviews conducted by law-enforcement personnel in this matter. Ms. Frady, however, was unable to perform said work due to a conflict of interest, and the project was undertaken by

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Vivian Erikson.
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Dockets.Justia.com

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Said transcriptions/translations are urgently necessary to prepare for the trial in this matter and also to conduct proper examinations of the witnesses testifying in said trial1. There are numerous cassette tapes containing eight interviews that required

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transcription and translation. Ms. Eriksen charges $45.50 per hour. Because these interviews require transcription of Spanish language followed by translation thereof, this work is very labor intensive. Ms. Eriksen translated and transcribed the following interviews: Oscar Meza-Licea (46 pp) Ramon Perez-Muņoz (42 pp) Ricardo Duran-Ortiz (13 pp)

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Carmelo Aroz-Araiza,(17 pp) Julio Cesar Baldenegro (25 pp) David Fraga-Chavez (8 pp) Miguel Sandoval-Perez (7 pp) Roberto Diaz-Garcia (8 pp) Ms. Eriksen's itemized statement is attached hereto as a related document. Ms. Eriksen spent 135.3 hours translating and transcribing the interviews. At

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$45.50 per hour, the total for this work is $6,156.15.
22 23 24 25 This is a complicated case involving 15 co-defendants and serious charges. The government has disclosed a large volume of evidence to defense counsel. In addition to the cassette tapes described herein, the government has disclosed approximately 1,200 pages of documents for defense counsel's review. 3000 more are expected. The case was recently designated as complex. 2
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Counsel has shared the transcripts with all defense counsel in the case, thereby minimizing costs. Wherefore, Defendant respectfully requests that the Court approve funds for

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Ms. Eriksen in excess of $500, to wit $6,156.15.
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RESPECTFULLY SUBMITTED this 9th day of October, 2007

By: s/ Peter Hormel Peter Hormel Attorney for Defendant Electronic copy of the foregoing to: U.S. Attorney's Office Angela Martinez 405 W. Congress Tucson, Arizona 85701 Counsel for co-defendants Counsel for Material Witnesses

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