Motion To Supplement The Record On Appeal

  • June 2020
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVSION CASE NO: 06-20395-CR-UNGARO/Simonton UNITED STATES OF AMERICA, Plaintiff, vs. DORIS TRAPP, Defendant. / MOTION TO SUPPLEMENT RECORD ON APPEAL COMES NOW, the Defendant/Appellant, DORIS TRAPP, by and through her undersigned attorney and files this motion to supplement the record on appeal in this cause and as grounds would state: 1. Appellant filed her Notice of Appeal in this cause on July 31, 2009. [DE 402] Appellant appeals the sentence imposed as a result of her violation of supervised release. 2.

That part of Defendants/Appellants appeal will involve the Pronouncement and

Judgment in a Criminal Case entered in the underlying substantive case, to wit: 08-20650-CRCOOKE. It was this substantive case that resulted in the Violation of Supervised Release in the instant matter. There was reference in the Pronouncement and Judgment in a Criminal Case in 08-20650-CR-COOKE to the sentence to be imposed in this case. 3. The transcript of the Sentencing Hearing conducted in Case Number: 08-20650-CRCOOKE [DE 421] on April 1, 2009 and the Judgment in a Criminal Case in that matter [DE 422] will be required for a complete record in this cause.

4. Undersigned counsel has contacted Michael Sofia, Assistant United States Attorney who handled the sentencing hearing in the above styled matter and he does not object to this request to Supplement the Record. WHEREFORE, Appellant respectfully requests this Honorable Court to enter an order directing the clerk of the district court to supplement the record on appeal with the transcript of the sentencing hearing held on April 1, 2009 in case number 08-20650-CR-COOKE [DE 421] and the Judgment in a Criminal Case entered on April 3, 2009 in case number 08-20650-CRCOOKE [DE 422]. JONATHAN S. FRIEDMAN, P.A. ONE EAST BROWARD BLVD. SUITE 925 WACHOVIA BANK TOWER FORT LAUDERDALE, FLORIDA 33301 TELEPHONE (954) 713-2820 FACSIMILE (954) 713-2894

_/S/ Jonathan S. Friedman_____ JONATHAN S. FRIEDMAN, ESQ. FLORIDA BAR NUMBER: 0973297

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 24, 2009, the undersigned attorney electronically filed the foregoing document with the Clerk of the Court, the United States Attorney's Office and other counsel of record, if any, using CM/ECF and has served same via U.S. Mail to those counsel(s) or individuals, if any, who are not authorized to receive electronically Notice of Electronic Filing.

_/S/ Jonathan S. Friedman_____ JONATHAN S. FRIEDMAN, ESQ. FLORIDA BAR NUMBER: 0973297

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