USA v. Wurie et al

MOTION to Remand to South Bay as to Brima Wurie.

D. Mass.June 4, 2004

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ________________________ UNITED STATES ) ) v. ) 03-CR-10168-WGY ) BRIMA A. WURIE ) ________________________) MOTION FOR BRIMA WURIE TO BE REMANDED TO SOUTH BAY Now comes Brima Wurie, who has this day been acquitted in the above-captioned matter, and moves that he be remanded to South Bay where he is serving a state sentence while awaiting trial on charges pending before Judge Saris and Magistrate-Judge Collings (United States v. Brima Wurie, No.: 03-10329-PBS). As reason therefor, Brima Wurie says that it is much more convenient for counsel, especially for out-of-state learned counsel, to visit him at South Bay while preparing for the potential death penalty case before Judge Saris, that his family can visit him regularly at South Bay, that he will finish serving his state sentence in October of this year and will then be held in Federal custody, and that trial in the case before Judge Saris is scheduled for January 2005. Therefore, Mr. Wurie’s being held at South Bay will cause no inconvenience to this Court, but will be efficient for his attorneys in the potential death penalty case and will permit Mr. Wurie to complete his state sentence. Case 1:03-cr-10168-WGY Document 126 Filed 06/04/04 Page 1 of 2 Respectfully submitted, BRIMA A. WURIE, By his attorneys, _______________________________ Norman S. Zalkind (B.B.O. # 538880) Zalkind, Rodriguez, Lunt & Duncan 65a Atlantic Avenue Boston, MA 02110 (617)742-6020 ______________________________ Elizabeth A. Lunt (B.B.O. # 307700) Zalkind, Rodriguez, Lunt & Duncan 65a Atlantic Avenue Boston, MA 02110 (617)742-6020 _______________________________ Carl J. Herman Suite 101 570 W. Mt. Pleasant Avenue Livingston, NJ 07039 (973)740-8944 Dated: June 4, 2004 CERTIFICATE OF SERVICE I hereby certify that a true copy of Motion for Brima Wurie to be Remanded to South Bay was served on June 4, 2004 by facsimile and first class mail to Theodore B. Heinrich, Assistant U.S. Attorney, U.S. Courthouse, Suite 9200, One Courthouse Way, Boston, MA 02210; and by mail to John H. Cunha, Jr., Cunha & Holcomb, PC, One State Street, Boston, MA 02109. ________________________________ Elizabeth A. Lunt Case 1:03-cr-10168-WGY Document 126 Filed 06/04/04 Page 2 of 2