IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Similar documents
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO CRIMINAL NO (PJB)

UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 8:18-cr TDC Document 35 Filed 10/23/18 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

Case 2:15-cr MMB Document 40 Filed 04/01/16 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 3:15-cv FAB-MEL Document 29 Filed 09/28/15 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Case 1:18-cr TSE Document 223 Filed 08/10/18 Page 1 of 5 PageID# 4200

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Dear Governor Rosselló Nevares, Senator Rivera Schatz, and Speaker Méndez Núñez:

Case 3:18-cr MMH-JRK Document 59 Filed 10/17/18 Page 1 of 5 PageID 149

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO OPINION AND ORDER. Before the Court is a motion to dismiss (No.

Case: LTS Doc#:111 Filed:05/25/17 Entered:05/25/17 13:40:50 Document Page 1 of 6

In the United States Court of Appeals For the First Circuit

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA


IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Case 1:19-cr ABJ Document 27 Filed 02/08/19 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION UNITED STATES OF AMERICA,

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA. The Honorable Judge Terri-Ann Miller, by and through undersigned

Case 1:12-cv MGC Document 155 Entered on FLSD Docket 02/13/2013 Page 1 of 8

Case 1:15-mc ESH Document 17 Filed 05/18/15 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case: 1:17-cv JG Doc #: 87 Filed: 01/11/19 1 of 5. PageID #: 1056 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

Bruce E. Blumberg BLUMBERG & ASSOCIATES UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) ) ) ) Case No: 04-CR-820-PHX-FJM

filed against him on February 2, 1995 from the counts contained in the same indictment against

Case 1:05-cr RBW Document 387 Filed 07/09/2007 Page 1 of 10 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 6:18-cr RBD-DCI Document 59 Filed 08/16/18 Page 1 of 9 PageID 393 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

Case 1:11-cr JSR Document 43 Filed 03/27/12 Page 1 of x x. Pending before the Court are defendant Rajat Gupta's

Case 1:18-cr Document 16 Filed 02/27/18 Page 1 of 3 PageID# 150 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

Case 2:15-cr JHS Document 126 Filed 09/07/17 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 1:16-cv FAM Document 13 Entered on FLSD Docket 07/12/2016 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ORDER

Case 3:14-cr GAG Document 64 Filed 07/08/15 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Case 1:19-cr ABJ Document 70 Filed 04/12/19 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 8:04-cv SCB-TBM Document 32 Filed 10/07/2005 Page 1 of 6

Case 3:07-cr JKA Document 62 Filed 12/12/2007 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION

BRIEF OF THE APPELLANT

Case 3:12-cr DRD-SCC Document 397 Filed 02/20/15 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA TO: UNITED STATES ATTORNEY THOMAS O BRIEN AND ASST. U.S

Case: 2:13-cr MHW-TPK Doc #: 56 Filed: 08/28/14 Page: 1 of 7 PAGEID #: 368

Case 1:12-cr LO Document Filed 07/31/12 Page 1 of 8 PageID# 1416 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA

Case 5:14-cv Document 51 Filed in TXSD on 05/29/18 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS LAREDO DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA PLAINTIFFS MOTION FOR CLARIFICATION OF SCHEDULING ORDER AND INCORPORATED MEMORANDUM OF LAW

United States Court of Appeals for the Federal Circuit

Case 2:08-cv RBS Document 15 Filed 10/06/2008 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 1:16-cv RNS Document 24 Entered on FLSD Docket 08/16/2016 Page 1 of 5

Case 6:13-cr JAJ-KRS Document 245 Filed 05/30/14 Page 1 of 17 PageID 1085 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division

Case 1:14-cr CRC Document 92 Filed 08/03/15 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. v.

Case 1:16-cv CMA Document 304 Entered on FLSD Docket 05/18/2017 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

NO IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, PLAINTIFF-APPELLEE,

Case 1:15-cv MGC Document 175 Entered on FLSD Docket 09/29/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA, Plaintiff, v. JUAN BRAVO-FERNANDEZ [1], HECTOR MARTINEZ-MALDONADO [2], Defendants. Criminal No.

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA HUNTINGTON DIVISION. v. Civil Action No. 3:

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

IN THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

Case 2:08-cv RBS Document 26 Filed 10/22/2008 Page 1 of 9 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 1:11-cv JEM Document 77 Entered on FLSD Docket 07/06/2011 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

IN THE SUPREME COURT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

OPPOSITION TO MOTION FOR STAY OF ENTRY OF JUDGEMENT

Case 3:15-cr AJB Document 11 Filed 06/10/15 Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No.: CIV-SEITZ/MCALILEY

THE FLORIDA SUPREME COURT. S. Ct. Case No.: SC15-1 District Court Case No.: 4D MEDYTOX SOLUTIONS, INC., SEAMUS LAGAN and WILLIAM G.

PlainSite. Legal Document. Florida Middle District Court Case No. 6:10-cv Career Network, Inc. et al v. WOT Services, Ltd. et al.

Case AJC Doc 327 Filed 04/19/19 Page 1 of 22 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION

Case: LTS Doc#:1806 Filed:11/15/17 Entered:11/15/17 21:06:01 Desc: Main Document Page 1 of 23

Case 2:10-cr MHT-WC Document 2277 Filed 02/09/12 Page 1 of 5

IN THE SUPREME COURT OF FLORIDA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION UNITED STATES OF AMERICA, ) CRIMINAL ACTION NO.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No CIV-HURLEY

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION

Case: 1:13-cr Document #: 24 Filed: 04/14/14 Page 1 of 8 PageID #:108

IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT APPELLANT S MOTION FOR RELEASE PENDING APPEAL

Case 1:18-cr DLF Document 71 Filed 10/25/18 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 3:06-cv JAF Document 1-1 Filed 03/23/2006 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO ACTION FOR:

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE SUPREME COURT OF FLORIDA CASE NO. THE STATE OF FLORIDA, Petitioner, vs. JORGE LUIS DOMINGUEZ, Respondent.

IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ORDER ON PLAINTIFF S MOTION FOR SUMMARY JUDGMENT

NO STATE OF TEXAS IN THE DISTRICT COURT WARREN KENNETH PAXTON, JR. COLLIN COUNTY, TEXAS

IN THE SUPREME COURT OF FLORIDA ANSWER AND AFFIRMATIVE DEFENSES AND MOTION FOR MORE DEFINITE STATEMENT

NO STATE OF TEXAS ) IN THE COUNTY COURT VS. ) AT LAW NUMBER FIVE JOE SMITH ) BEXAR COUNTY, TEXAS

Case: LTS Doc#:3865 Filed:09/05/18 Entered:09/05/18 18:31:09 Document Page 1 of 18

Case: 1:16-cr TSB Doc #: 229 Filed: 11/22/17 Page: 1 of 6 PAGEID #: 5045 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

Case 1:16-cv FAM Document 30 Entered on FLSD Docket 08/16/2016 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Hitachi, Ltd. - Cooperation and Non-Prosecution Agreement

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA CONDOMINIUMS, TIMESHARES AND MOBILE HOMES

Case5:09-cr RMW Document165 Filed05/28/10 Page1 of 7

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI 2015-CA STATE OF MISSISSIPPI MOTION FOR REHEARING

Case 3:14-cr JRS Document 413 Filed 08/15/14 Page 1 of 14 PageID# 9631

EEOC v. Moka Shoe Corporation

Case 1:15-cr KMW Document 23 Filed 09/04/15 Page 1 of 15 MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS MOTION FOR A BILL OF PARTICULARS

Case: LTS Doc#:11-24 Filed:06/19/17 Entered:06/19/17 21:15:29 Exhibit Exhbit 17 Motion Page 1 of 5

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO. No. 16 CR 1106 JB

Transcription:

UNITED STATES OF AMERICA, Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO v. CRIMINAL NO. 08-00036 (PJB) ANÍBAL ACEVEDO VILÁ, et al., Defendants. DEFENDANT LUISA INCLAN BIRD S MOTION TO DISMISS COUNT 1 (CONSPIRACY) ON GROUNDS OF VAGUENESS 1 AND INCORPORATED MEMORANDUM OF LAW Defendant, Luisa Inclan Bird, through undersigned counsel, hereby moves this Court to dismiss Count 1 of the Superseding Indictment (the Indictment ) on grounds of vagueness. We submit that it is impossible to tell whether Count One describes one or multiple conspiracies; what acts of different defendants and co-conspirators, if any, relate to Defendant Inclan Bird; what agreement, if any, is attributed to Defendant Inclan Bird; and what Defendant Inclan Bird actually knowingly did to become a member of the charged conspiracy. Accordingly, we submit that Count One of the indictment is impermissibly vague. In support of this motion, the Defendant states as follows. Count One charges conspiracy. It focuses on the time period between September 1999 and June 30, 2003 and relates to alleged activities occurring in connection with the candidacy of co-defendant Acevedo Vila as Resident Commissioner to the United States House of Representatives for the Commonwealth of Puerto Rico. Count One alleges a purported unitary conspiracy to make and receive contributions to the Resident Commissioner campaign in excess 1 Defendant Candido Negron Mella has joined in the instant motion.

of the limits of 2 U.S.C. Section 441a; to make and receive contributions from monies belonging to corporations contrary to 2 U.S.C. Section 441b; to make and receive conduit contributions contrary to 2 U.S.C. Section 441f; to make and receive contributions by foreign nationals in violation of 2 U.S.C. Section 441e; to make false reports to the Federal Election Commission ( FEC ) in violation of 2 U.S.C. Section 434(b); to make false statements to the FEC, contrary to 18 U.S.C. Section 1001(a)(2); and to falsify and conceal material facts from the FEC in violation of 18 U.S.C. Section 1001(a)(1). The Indictment describes Puerto Rico Collaboration Contributions (Indictment at p. 8); family and staff contributions (Indictment at p. 9) and Philadelphia contributions (Indictment at pp. 10-13). Luisa Inclan Bird obtained a LLM from Cornell University Law School in 1987. For years thereafter, Defendant Inclan Bird had a successful and busy law practice in Puerto Rico. Around 1998 and after the birth of her daughter, Defendant Inclan Bird began to work with Anibal Acevedo Vila as an external legal consultant. Pursuant to the terms of the contract Ms. Luisa Inclan Bird had when Defendant Acevedo Vila was Resident Commissioner, Ms. Luisa Inclan Bird would at times work out of the Resident commissioner s office in San Juan. Ms. Luisa Inclan Bird performed volunteer work fundraising on limited occasions on Defendant Acevedo Vila s Resident Commissioner campaign. During the Resident Commissioner s campaign, Ms. Luisa Inclan Bird was NOT an officer of the campaign and did not have any formal campaign or any management role. In or around 2004, Ms. Luisa Inclan Bird decided to resign her existing Government contract in order to become a full time employee of the Popular Democratic Party (the Party ) to help with Defendant Acevedo Vila s campaign for Governor. Ms. Luisa Inclan Bird worked in the Finance Department of the Governor s campaign and NOT in the Finance Department of 2

the Party. It must be noted that the Finance Department of the Party was directed by Co- Defendant Ricardo Colon and the campaign s Finance Chair was Co-Defendant Miguel Nazario. The idea that Luisa Inclan Bird had anything to do with the conspiracy alleged in Count One is belied by her true responsibilities and also by the facts. Nor does the language of Count One adequately explain how Defendant Inclan Bird could be charged with a crime. Defendant Inclan Bird is mentioned twice in connection with the Count One conspiracy. The Indictment alleges as overt acts that in October 2001 Defendant Inclan Bird requested a staffer to provide two campaign contribution checks in favor of the Acevedo Vila candidacy for Resident Commissioner totaling $1,000 and later reimbursed this person for the contributions (Indictment at p. 17, overt acts, paragraphs 19-20). Out of more than fifty overt acts, these are the only overt acts mentioning Defendant Inclan Bird. The Indictment is silent as to how a $1,000 contribution in the Fall of 2001 is material to the offense charged. There is also a reference to Defendant Inclan Bird at page 24 in paragraph 45 that in the Fall of 2003 and after the period during which the alleged conspiracy operated, that Ms. Luisa Inclan Bird assisted in coordinating a meeting with the Puerto Rico Pension Fund. Ms. Luisa Inclan Bird and others routinely arranged meetings between Puerto Rico Government officials and third parties as part of the ordinary duties of the Office of the Governor. The Indictment is silent as to how the performance of a routine duty could be part of any alleged crime. Count One of the Indictment is unclear as to which, if any, illegal agreement Defendant Inclan Bird allegedly joined, or when, or how a $1,000 contribution materially furthered the supposed conspiracy or how the disparate acts identified form a single, unified conspiracy as opposed to independent and multiple conspiracies. 3

A. Vagueness When the legality of a person s conduct is challenged under the dictates of a criminal statute, the Supreme Court has declared that [n]o one may be required at peril of life, liberty or property to speculate as to [the statute s] meaning All are entitled to be informed as to what the State commands or forbids. Lanzetta v. New Jersey, 306 U.S. 451, 453 (1939). Because of the serious consequences of vagueness in criminal statutes, courts must construe them rigorously in order to protect unsuspecting citizens from being ensnared by ambiguous statutory language. United States v. Insco, 496 F.2d 204, 206 (5th Cir. 1974). See also Kropp Forge Co. v. Secretary of Labor, 657 F.2d 119, 122 (7th Cir. 1981) (approving the traditional rule that the applicability of penal sanctions in regulations is to be narrowly construed by the judiciary ). Due process requires that statutes give fair warning to persons of ordinary intelligence of the proscribed conduct and the persons covered. See Owens v. Wainwright, 698 F.2d 1111, 1115 (11th Cir. 1983). Moreover, Fed. R. Crim. P. 7(c) requires that an Indictment contain a plain, concise and definite written statement of the essential facts constituting the offense charged. This rule is grounded in the Fifth Amendment guarantee of indictment by grand jury and the Sixth Amendment right to be informed of the nature of the charges. See United States v. Dorfman, 532 F. Supp. 1118, 1124 (N.D. Ill. 1981). The Indictment must adequately inform the defendant of the charge against her so that she can prepare her defense; and it must establish a record for the purpose of ruling on a defense of double jeopardy should defendant be prosecuted again. See Russell v. United States, 369 U.S. 749 (1962). While Count One of the Indictment generally tracks the statutory language of 18 U.S.C. Section 371, it falls far short of describing in any coherent way how Defendant Inclan Bird s conduct violates the law. 4

CONCLUSION Because Count One fails to adequately apprise Defendant Inclan Bird of the nature of the allegations against her, it should be dismissed. Respectfully submitted, s/ Michael S. Pasano Florida Bar No. 0475947 E-mail: mpasano@carltonfields.com Paul A. Calli, Esq. Florida Bar No. 0994121 E-mail: pcalli@carltonfields.com CARLTON FIELDS 100 S.E. 2nd Street 4000 International Place Miami, Florida 33131-2114 Telephone: (305) 530-0050 Toll Free: 800-486-0140 Facsimile: (305) 530-0055 Attorneys for Defendant Luisa Inclan-Bird 5

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been filed via electronic mail with the Clerk of the Court by using CM/ECF System which will send a notice of electronic filing to the following on this 8 th day of July, 2008. AUSA Maria Dominguez Torre Chardon, Suite 1201 350 Carlos Chardon Street Suite 1201 San Juan, Puerto Rico 00918-1111 787-282-1806 E-mail: maria.a.dominguez@usdoj.gov Harry Anduze-Montano, Esq. 1454 Fernandez Juncos Avenue San Juan, Puerto Rico 00909 787-723-7171 E-mail: handuze@microjuris.com Attorney for Anibal Acevedo-Vila Francisco Rebollo-Casalduc, Esq. P.O. Box 195571 San Juan, Puerto Rico 00919 787-765-0505 E-mail: frc@onelinkpr.net Attorney for Candido Negron-Mella Michael M. Mustokoff, Esq. Duane Morris 30 South 17 th Street Philadelphia, PA 19103-4196 215-979-1818 E-mail: mmustokoff@duanemorris.com Attorney for Salvatore Avanzato Eliseo Roques, Esq. Martinez, Odell & Calabria Banco Popular Center Sixteenth Floor P.O. Box 190998 Hato Rey, Puerto Rico 00919-0998 787-274-2921 E-mail: era@mocpr.com Attorney for Luisa Inclan-Bird Thomas C. Green, Esq. Sidley & Austin, LLP 1501 K Street, N.W. Washington, DC 20005 202-736-8069 E-mail: tcgreen@sidley.com Attorney for Anibal Acevedo-Vila Thomas R. Lincoln, Esq. P.O. Box 363852 San Juan, Puerto Rico 00936-3852 787-292-1099 E-mail: tomlincoln@onelinkpr.net Attorney for Salvatore Avanzato Maria H. Sandoval, Esq. P.O. Box 9878 San Juan, Puerto Raico 00908 787-282-0281 E-mail: mhsandoval@att.net Attorney for Jorge Belasco-Mella 6

Henry E. Hockeimer, Esq. Ballard, Spahr, Andrews & Ingersoll, LLP 1735 Market Street Philadelphia, PA 19103 215-864-8204 E-mail: hockeimerh@ballardspahr.com Attorney for Robert M. Feldman Thomas M. Gallagher, Esq. Pepper Hamilton LLP 3000 Two Logan Square Eighteenth and Arch Streets Philadelphia, PA 19103-2799 215-981-4068 E-mail: gallaght@pepperlaw.com Attorney for Marvin I. Block Hector E. Guzman-Silva, Esq. Joseph C. Laws, Esq. Federal Public Defender s Office 241 Franklin D. Roosevelt Avenue Hato Rey, Puerto Rico 00918-2441 787-281-4922/4927 E-mail: hector_guzman@fd.org E-mail: joseph_laws@fd.org Attorney for Edwin Colon-Rodriguez Richard O. Dansoh, Esq. 2600 Douglas Road PH #7 Coral Gables, Florida 33134 305-573-4444 E-mail: rodanosh@aol.com Attorney for Miguel Nazario-Franco Diego A. Ramos, Esq. Roberto A. Camara-Fuertes, Esq. Fiddler, Gonzalez & Rodriguez P.O. Box 363507 San Juan, Puerto Rico 00936-3507 787-759-3162 787-759-3220 E-mail: dramos@fgrlaw.com E-mail: rcamara@fgrlaw.com Attorney for Marvin I. Block Juan R. Acevedo-Cruz, Esq. Banco Cooperativo Plaza Suite 501-A 623 Avenue Ponce de Leon San Juan, Puerto Rico 00917 787-751-2341 E-mail: jracevedo@coqui.net Attorney for Ramon Velasco-Escardille Jose R. Aguayo, Esq. 569 Tn. Cesar Gonzalez Street San Juan, Puerto Rico 00918 787-765-0814 E-mail: joseraguayo@cs.com Attorney for Miguel Nazario-Franco Ramon A. Cestero, Jr., Esq. Tres Rios Building, Suite 300 27 Gonzalez Giusti San Patricio Guaynabo, Puerto Rico 00968 787-250-8040 E-mail: racestero@hotmail.com Attorney for Ricardo Colon-Padilla 7

Roberto Buso-Aboy, Esq. Buso Aboy Law Office Westerbank World Plaza 268 Munoz Rivera Avenue Suite 1905 San Juan, Puerto Rico 00918-1931 787-250-7172 E-mail: busoaboy@prtc.net Attorney for Ricardo Colon-Padilla Antonio Moreda-Toledo, Esq. Moreda & Moreda P.O. Box 366066 San Juan, Puerto Rico 00936-6066 787-754-6290 E-mail: moreda@prtc.net Attorney for Jose Gonzalez-Freyre Joaquin Monserrate-Matienzo, Esq. 606 Munoz Rivera Avenue San Juan, Puerto Rico 00918 787-764-8960 E-mail: jmm@monserratelaw.com Attorney for Jose Gonzalez-Freyre Irma R. Valldejuli-Perez, Esq. P. O. Box 361228 San Juan, Puerto Rico 00936-1228 787-754-6290 E-mail: irvalldejuli@moredalaw.com Attorney for Jose Gonzalez-Freyre Francisco M. Dolz-Sanchez P.O. Box 361451 San Juan, Puerto Rico 00936-1451 787-759-8780 Attorney for Eneidy Coreano-Salgado s/ Michael S. Pasano 8