Opinion
19 Cr. 536 (PKC)
03-22-2022
U.S. v. DEEJAY WHITE, Defendants.
MOSKOWITZ & BOOK, LLP Avraham C. Moskowitz Counsel to Defendant DeeJay White
MOSKOWITZ & BOOK, LLP
Avraham C. Moskowitz
Counsel to Defendant DeeJay White
HON. P. KEVIN CASTEL, UNITED STATES DISTRICT JUDGE.
Dear Judge Castel:
This letter is respectfully submitted to request authorization, nunc pro tunc, for the use of my firm's associate Christopher R, Neff, to assist me in the above captioned case.
I have been a member of the CJA panel in the Eastern and Southern District since I left the U, S, Attorney's Office in 1991, During my entire tenure as a CJA attorney, I have routinely used associates and paralegals to help me represent my court-appointed clients, just as I do on my retained cases. Doing so allows me to give my CJA clients the personal attention they deserve at a cost below that which would be incurred if I provided all the services myself. Moreover, given the numerous pending matters that I am currently handling, the assistance of Mr. Neff was necessary in order for me to handle this matter appropriately and in a timely fashion.
Since 1996, when I started my own firm, I have always employed one or more full-time associates and paralegals. Currently, I employ one-full-time associate. Mr. Neff, who has been working for my firm for approximately ten years, is experienced in handling criminal matters and is highly skilled. He clerked for Judge Batts in the Southern District for two years before joining my firm. Since joining my firm, he has assisted me in representing dozens of clients in criminal matters and has even assisted me in handling a lengthy and complex criminal trial in New York State Supreme Court, New York County,
In light of the above, it is respectfully requested that the Court authorize my use of Mr. Neff, nunc pro tjmc on this matter. Given the fact that he is a full-time employee of my firm and represents a substantial portion of my firm's overhead, it is further requested that the Court authorize me to bill Mr. Neff s time at ¶ 10 per hour, a rate that has previously been approved by numerous judges in this District and in the Eastern District of New York.
Because this letter deals with defense funding it is being submitted ex parte, with a request that it be filed under seal.
Thank you in advance for your consideration of this application.
EX PARTE MOTION FOR APPROVAL TO FILE UNDER SEAL
This application is filed ex parte and under seal pursuant to LCrR 12.2 because it concerns information related to defense strategy that should not be made available to the other parties to this litigation. See Administrative Office of the United States Courts, GUIDELINES for the Administration of the Criminal Justice Act, Section 640, 20.
NOW COMES DeeJay White, by and through his attorney, Avraham C. Moskowitz, and respectfully moves, ex parte, for approval from the Court to file under seal a letter on behalf of defendant, requesting the use of an Associate.
WHEREFORE counsel respectfully request that the relief sought be granted.
On this 18h day of March 2022, it is
Sealing Application is GRANTED.
SO ORDERED.