Letter to Judge Kaplan, Appointment of Associate Counsel — United States v. Heaven West (S.D.N.Y., Dkt. 53)

Summary

An ex parte letter dated December 6, 2022 to United States District Judge Lewis A. Kaplan in United States v. Heaven West, 21 cr. 729 (LAK), from counsel who writes that counsel represents Heaven West. The letter requests the appointment of associate counsel under the Criminal Justice Act (CJA) and names Ms. Sahli, describing her experience and education. It states that a jury trial is scheduled for January 17, 2023 and that a grand jury indicted Ms. West on one count of wire fraud and one count of conspiracy to commit wire fraud. A proposed order section asks that Ms. Sahli be compensated at $90.00 per hour for 50 hours, citing 18 USC 3006A.

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KIRION LAW FIRM | pocunmnrr

i

DOCH
| DATE FILED: |2-¥-29272.

Marton G. Kirton, Esq. Nassau County:

175 Fulton Avenue, Suite 305
Hempstead, New York, 11550
Tel, # (516) 833-5617

Fax, # (516) 833-5620

December 6, 2022

VIA ELECTRONIC MAIL
EX PARTE

Honorable Lewis A. Kaplan
United States District Judge
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street

New York, NY 10007

Re: United States v. Heaven West, 21 cr. 729 (LAK)
Dear Judge Kaplan:

I represent Heaven West in the above-referenced matter. I request the appointment of
associate counsel pursuant to the Criminal Justice Act (CJA). This Court scheduled a jury trial
for January 17, 2023.

BACKGROUND

A Grand Jury indicted Ms. West on one count of wire fraud and one count of conspiracy
to commit wire fraud. Ms. West faces a thirty-year sentence. A multiple-defendant trial is
scheduled for January 17, 2023. The Government has turned over the Rule 16 discovery.

ASSOCIATE COUNSEL

I request that this Court appoint Emilee A. Sabli as my associate counsel.' Ms. Sahli has
over eight years of experience in complex criminal cases in the Southern District of New York.
She is an attorney admitted to practice in New York State and the Southern District of New
York. She is a 2016 City University of New York Law School (CUNY) graduate. She was on
CUNY 's Law Review and a member of the Criminal Defense Clinic. She has worked for the past

1 Please see the attached cv.

1
eight years with Emma Greenwood of the Greenwood Law Group, PLLC.’ She has worked on
several high-profile cases in the Southern District of New York. [ have worked with her in
United States v. Alexei Saab, 19 cr. 676 (PGG).? I have worked with her on other cases as
Associate counsel in the Southern District of New York. Ms. Sahli is in the CJA Mentoring
program in the Eastern District of New York. Ms. Sahli will assist me with pretrial preparation.
She will help me with organizing the Rule 16 discovery, compiling exhibits, consulting with Ms.
West, and consulting with me on all matters concerning this case. Given the volume of discovery
and the complexity of conducting a fraud trial in the Southern District of New York, Ms. Sahli's
services are necessary within the meaning of 18 USC 3006A.

PROPOSED ORDER
I request that Ms. Sahli be compensated at $90.00 per hour for 50 hours. The hourly rate
is reasonable and is in line with the rates suggested by the Second Circuit for Associate
Counsel.* The discovery, in this case, is voluminous, and the case is complex. I will create a trial

budget if necessary.

Please contact me if you have any questions or concerns.

suo

Sincerely,

ALB,

usps

? Ms. Sahli has started her own law firm.
3 Mr. Saab is charged with providing material support to a designated foreign terrorist organization.
4 Second Circuit Policy and Procedure Manual, Appendix E.

2


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