PRESERVING ERROR, PSR OBJECTIONS, & APPELLATE PROCEDURE - - PowerPoint PPT Presentation

PRESERVING ERROR, PSR OBJECTIONS, & APPELLATE PROCEDURE

Federal Criminal Law Update Webinar Federal Public Defender’s Office for the Western District of Texas Kristin Kimmelman, AFPD August 20, 2020

PRESERVING ERROR

Why does it matter? – avoid plain error review

■ To prevail on plain err plain error, must show: –

• 1. Error (deviation from legal rule that was not waived)

–

• 2. Plain (clear or obvious; not subject to reasonable dispute;

based on law at time of appeal) –

• 3. Affects substantial rights (prejudices defendant;

reasonable probability outcome would have been different) –

• 4. Seriously affects the fairness, integrity or public reputation
• f judicial proceedings (discretionary)

■ In contrast, to prevail on harml harmless ss err error, must show: –

• 1. Error

–

• 2. Affects substantial rights

– See Fed. R. Crim. P. 52

Pretrial Motions – Rule 12(b)

■ Motions that must be made before trial (“if the basis for the motion is then reasonably available and the motion can be determined without a trial on the merits”) – Rule 12(b)(3) – Defect in instituting the prosecution

■ improper venue, preindictment delay, violation of constitutional right to a speedy trial, selective or vindictive prosecution, error in grand-jury proceeding or preliminary hearing

– Defect in indictment or information

■ Duplicity, multiplicity, lack of specificity, improper joinder (Rule 8), failure to state an

• ffense

– Suppression of evidence – Severance of charges or defendants (Rule 14) – Discovery (Rule 16) ■ Motion that court lacks jurisdiction can be made at any time while case is pending

Pretrial Motions – Rule 12(b)

■ Motions that must be filed pretrial must be filed timely – Rule 12(c): court can set pretrial motions deadline; otherwise, deadline is start

• f trial

– Local Rule CR-12(a) (W.D. Tex.): unless otherwise ordered by court, pretrial motions deadline is 14 days after arraignment; if arraignment waived, within 14 days of latest scheduled arraignment

■ Check court’s standing orders and discovery orders ■ Ask for an extension of time

■ Otherwise, must show good cause for untimely filing – E.g., 5C treated a suppression issue as preserved even though motion filed midway through trial; defense counsel not aware until agent testified that Tello was detained to allow the dog to continue to search the vehicle

■ US v. Tello, 924 F.3d 782 (5C 2019)

Example: post-verdict motion arguing statute doesn’t apply extraterritorially is untimely  unpreserved (but not waived)

■ US v. Vasquez, 899 F.3d 363 (5C 2018) – Extraterritoriality was not jurisdictional challenge to RICO murder prosecution – Post-verdict motion was untimely – Argument was unpreserved, but not “waived”

■ “Waiver” ordinarily entails “the intentional relinquishment or abandonment of a known right.” ■ Rule 12 amended in 2014 to change consequence of late motion to being “untimely” instead of “waived” ■ Therefore, considered for plain error

– Court held no error, plain or otherwise, because Congress clearly and affirmatively indicated the RICO statute applies extraterritorially

Pretrial Motions – Preservation Tips

■ Set forth enough facts to warrant favorable ruling – Otherwise, district court does not have to hold an evidentiary hearing ■ Argue all applicable theories – E.g., motion to suppress statements because of Miranda violation won’t preserve suppression based on other theory ■ Unconditional guilty plea w Unconditional guilty plea waiv ives all es all non-ju non-jurisdictional def risdictional defects e cts except ch cept challenge t allenge to constitutionality of statut constitutionality of statute – To preserve other issues, such as suppression of evidence, must do conditional plea, stipulated bench trial, or regular trial – See Class v. US, 138 S. Ct. 798 (2018); US v. Coil, 442 F.3d 912, 914 (5th Cir. 2006); US v. Torres, 740 F. App'x 54, 55 (5th Cir. 2018)

Preserving with a Conditional Plea

■ Conditional pleas exist in the WDTX – USAO does not have blanket policy against them (per Najera argument) ■ Conditional pleas per Rule 11(a)(2): – In writing – Consent of court and the government – Reserve right to have appellate review of specific pretrial motion ■ 5C relaxes these Rule 11(a)(2) requirements if record clear that defendant intended to enter a conditional guilty plea and to appeal particular pretrial ruling, and neither government nor district court opposed such a plea – See US v. Wise, 179 F.3d 199 (5C 1999)

Preserving with a Stipulated Bench Trial

■ For stipulated bench trial, make it clear for the record (in writing or orally); – Only entering into stipulations because of the court’s adverse ruling, – Stipulated facts include the evidence that should have been suppressed (so the pretrial ruling harms the defendant), – Government unwilling to do conditional plea, and – Client is not admitting guilt. ■ Should still get the 2 points for acceptance of responsibility if do not deny factual elements and just reurge pretrial motion at bench trial – US v. Najera, 915 F.3d 997 (5C 2019) ■ But government could elect to withhold the third point because of the “resources expended litigating a suppression motion” – US v. Longoria, 958 F.3d 372 (5C 2020) (circuit split)

Proffer, Proffer, Proffer

■

• Fed. R. Evid. 103(a)(2): to preserve error of excluding evidence, party must inform

court of “its substance by an offer of proof, unless the substance was apparent from the context” ■ Best practice to give: – 1) a detailed summary of the substance of the excluded evidence; – 2) all all the things you expect to show or prove by that evidence; and and – 3) all all the grounds on which the evidence should be admitted. ■ The proffer principle applies outside of trial as well – E.g., 5C affirmed denial of CJA attorney’s request for an investigator when request not detailed enough about need and why defense counsel couldn’t do it – US v. Gadison, 8 F.3d 186 (5C 1993)

Contemporaneous Objection Rule

■ To preserve error when evidence is admitted, you must: – 1) timely object or move to strike, and – 2) state the specific ground.

• Fed. R. Evid. 103(a)(1)(A); see Fed. R. Crim. P. 51(b)

■ Continuing objection can preserve error if court grants it, and it’s clear what the objection covers – But 5C cautions against a pretrial grant of a continuing objection – US v. Sanchez-Hernandez, 507 F.3d 326 (5C 2007); US v. Fortenberry, 919 F.2d 923 (5C 1990) ■ Motion in limine preserves issue (without a later objection) if – sufficiently specific, and – definitively ruled on pretrial. – US v. Lucas, 849 F.3d 638 (5C 2017) ■ If the MIL ruling was not definitive, you must still object when the evidence is admitted if the court did not definitively rule earlier – But can use the MIL as a shorthand for the objection ground ■ For Rule 609, must “run the gauntlet” to preserve – testify and then be impeached by priors – If you decide to take out the sting, error no longer preserved – Luce v. US, 469 U.S. 38 (1984); Ohler v. US, 529 U.S. 753 (2000)

Trial – Motion for Judgment of Acquittal

■ To preserve challenge to the sufficiency of the evidence, move for judgment of acquittal: – 1) at close of government’s case, and – 2) at close of defense case. –

• Fed. R. Crim. P. 29(a)

■ A general motion preserves insufficiency of evidence to support verdict (but not venue) – But where “a defendant asserts specific grounds for a specific element of a specific count for a Rule 29 motion, he waives all others for that specific count” – US v. Herrera, 313 F.3d 882 (5C 2002) (en banc); US v. ■ Can still preserve with a post-verdict motion for judgment of acquittal within 14 days of verdict – Rule 29(c) – But this doesn’t invoke the double jeopardy bar – US v. Villarreal, 324 F.3d 319 (5C 2003) ■ If unpreserved, sufficiency claims reviewed for “manifest miscarriage of justice”

Trial – Jury Instructions

■ You can request certain instructions in writing, and must do so at the close of evidence or at any earlier time reasonably set by the court –

• Fed. R. Crim. P. 30(a)

■ To preserve error, your objection must be: – Timely (before jury retires to deliberate), and – Sufficiently specific ■ Make sure the charge conference is on the record! – Filing your proposed jury instructions before the charge conference is insufficient ■ When in doubt, file written objections

Guilty Pleas

■ Failure to comply with Rule 11 reviewed for plain error unless objected to – 5C can review entire record when evaluating substantial rights ■ Tip: use the 5C’s Ander’s checklist to make sure they court doesn’t miss anything at time of plea

Sentencing – PSRs

■ Before PSR interview, think about what information you want to be in the PSR – Attend PSR interview ■ Rev Review P PSR w with t the c client – see Fed. R. Crim. P. 32(i)(1)(A) (court will verify defendant and attorney read the report and any addendum) – Check facts as well as Guidelines – Check criminal history – even the convictions and arrests that don’t score

■ These could matter for BOP purposes

– Go over supervised release conditions, especially any special ones ■ The PSR will follow the client through BOP and any future cases

Sentencing – PSRs

■ Object t Object to Guidelines Guidelines err errors – Does not help to ignore Guidelines error so that you have an issue to appeal

■ Yes, some judges actually think we do this – See Del Carpio argument

– Supreme Court recognized such “sandbagging” was unlikely because:

■ Doesn’t account for realities at play in sentencing proceedings (Guidelines starting point) ■ Ethical obligations to zealously represent client and duty of candor to the court ■ No guarantee of remand – Rosales-Mireles v. US, 138 S. Ct. 1897 (2018)

Sentencing – PSRs

■ Even though Guideline error may be plain, still have to show: – Affects substantial rights

■ Molina-Martinez v. US, 136 S. Ct. 1338 (2016), held being sentenced under an incorrect Guidelines range (even if ultimate sentence was within correct range) “can and most often will, be sufficient to show a reasonable probability of a different outcome” ■ But 5C has still affirmed - see US v. Sanchez-Hernandez, 931 F.3d 408 (5C 2019) (original sentence was upward variance); US v. Johnson, 943 F.3d 735 (5C 2019) (same)

– Affects fairness, integrity, and public reputation of proceedings

■ Rosales-Mireles held a plain Guidelines error that affects substantial rights “ordinarily warrants relief” on plain error review ■ But 5C has still affirmed - see US v. Fuentes-Canales, 902 F.3d 468 (5C 2018) (2019) (facts of burglary would warrant upward departure even if not COV)

Sentencing – PSRs

■ Even if reversed, typically goes back to sentencing judge – Could impose same sentence or even higher if rebuts presumption of vindictiveness

■ See US v. Penado-Aparicio, No. 19-50401, 2020 WL 4691896 (5C Aug. 12, 2020) (vacating vindictive sentence)

Sentencing – examples of Guidelines errors

■ Using the right Guidelines Manual version – 1B1.11 – Use Manual in effect on date of sentencing – Unless doing so would violate the ex post facto clause, then use Manual in effect at date of offense – Use that Manual in its entirety ■ Whether a conviction is a crime of violence or controlled substance offense – 4B1.2 – Analysis involves categorical approach – Applies to many guidelines, including 2K2.1 and 4B1.1 – 4B1.2 COV definition amended to exclude burglary (but upward departure possible) – Texas distribution is not a CSO – US v. Tanksley, 848 F.3d 347 (5C 2017)

Sentencing – examples of Guidelines errors

■ Mechanics of mitigating role in high drug guideline cases – 2D1.1(a)(5) – Get extra levels off (in addition to 3B1.2 reduction) for mitigating role – If meth and get mitigating role, no extra 2 levels for importation – 2D1.1(b)(5) ■ Whether a conviction is a felony – 2L1.2 – Look at maximum possible sentence the client could have received – Some states have mandatory sentencing schemes – e.g., KS, NC, TN, WA

■ See US v. Simmons, 649 F.3d 237 (4th Cir. 2011)

■ When sentenced under money laundering guideline, Chapter 3 enhancements must be based on the money laundering conduct, not the conduct of the underlying

• ffense (e.g., wire fraud) – 2S1.1 Note 2(C)

– See US v. Del Carpio Frescas, 932 F.3d 324 (5C 2019)

Sentencing – examples of Guidelines errors

■ Whether multiple prior sentences are counted separately or as one – 4A1.2(a)(2) – Counted separately if:

■ Imposed for offenses separated by intervening arrest ■ If no intervening arrest, separate unless – Offenses in same charging instrument OR – Sentences imposed on same day

■ Whether an old conviction scores – 4A1.2(e) – What scores:

■ More than 13 months’ imprisonment imposed within 15 years of commencement

• f instant offense or resulting in incarceration during those 15 years

■ 13 months or less if imposed within 10 years of commencement of instant offense

Sentencing – examples of Guidelines errors

■ If sentenced to multiple counts, Guidelines sentence (total punishment) could be above the statutory maximum for any particular count – 5G1.2(d) ■ If client has undischarged term of imprisonment for offense (and the instant offense was committed before that imprisonment or sentencing) that is relevant conduct to the instant offense under 1B1.3(a)(1)-(3), then: – Adjust sentence for any period of incarceration BOP won’t credit, and – Run instant offense concurrently – 5G1.3 ■ If statutorily authorized max term of imprisonment upon revocation is less than applicable range, the statutory max is the applicable range – 7B1.4(b)(1), (3)(A) – Max related to class of the underlying felony – 18 USC 3583(e)(3)

Sentencing – PSRs & factual issues

■ Party seeking adjustment has burden to prove it applies by preponderance of the sufficiently reliable evidence – USSG 1B1.1 – Unsworn statements are not, by themselves, sufficiently reliable evidence ■ PSR generally considered to have sufficient indicia of reliability ■ On appeal, factual issues such as relevant conduct, loss amount, and minor role are reviewed for clear error: – No clear error if plausible in light of record as a whole – Clear error if review of all evidence leaves “definite and firm conviction that a mistake has been committed” – See US v. Aguilar-Alonzo, 944 F.3d 544 (5th Cir. 2019) (clear error to apply 2-level adjustment for use of affection) ■ Used to be factual errors that were not objected to would not be considered on appeal – But Supreme Court overruled that 5C precedent in Davis v. US, 140 S. Ct. 1060 (2020), without merits briefing or oral argument

Sentencing – PSRs & factual issues

■ To challenge facts in the PSR (e.g., drug quantity, role, loss amount), must rebut them with evidence (e.g., affidavit) – Otherwise, court can accept facts in PSR without further inquiry or explanation

■ But PSR must state basis for those facts

– Make sure evidence (e.g., letters, pictures, expert reports) is part of record e.g., exhibits to sentencing memo – US v. Barfield, 941 F.3d 757 (5C 2019) (court could rely on defendant’s post- arrest statement even though defendant objected to its reliability; no rebuttal evidence) ■ Consider asking for an evidentiary hearing to resolve disputed fact ■ See US v. Dabeit, 231 F.3d 979 (5C 2000); US v. Mitchell, 166 F.3d 748 (5C 1999); US v. Patterson, 962 F.2d 409 (5C 1992); US v. Alfaro, 919 F.2d 962 (5C 1990)

Sentencing – Non-custodial aspects

■ Object to supervised release conditions that are: – Not reasonably related to 3553 factors, or – Not narrowly tailored (deprive client’s liberty more than necessary) – 18 U.S.C. 3583(d) ■ Object to supervised release conditions that impermissibly delegate judicial authority to probation officers – E.g., requirement to follow therapist’s lifestyle restrictions (Morin); allowing PO to decide whether defendant had to participate in treatment (Franklin) ■ Object to restitution that is not required or supported by the evidence – Consider asking for evidentiary hearing – Consider asking for a payment schedule – see Page 6 of https://www.uscourts.gov/sites/default/files/ao245b.pdf

Sentencing – Preservation Tips

■ Object to PSR in writing and orally at sentencing hearing ■ File written sentencing memo that identifies reasons for downward departure or variance; include exhibits to ensure they are in the record ■ Raise all grounds for the objection; grounds not raised will be subject to plain error ■ Be specific enough to allow the court to address the error – Vague or pro forma objections will not suffice ■ To preserve other procedural errors, object at sentencing noting the procedural error (e.g., failing to consider 3553 factors, sentencing based on clearly erroneous facts,

• r failing to adequately explain sentence)

– If court then gives an explanation, say something like “the objection stands” ■ To preserve substantive error (unreasonable sentence), argue for a lower sentence – A formal objection after sentence announced is no longer necessary – Holguin-Hernandez v. US, 140 S. Ct. 762 (2020)

Sentencing – SOR

■ Check statement of reasons for accuracy – If it doesn’t reflect sustained objections, ask probation officer about amended PSR or appending sentencing transcript to PSR – Otherwise, BOP won’t know about changes – See Fed. R. Crim. P. 32(i)(3)(C)

APPELLATE PROCEDURE

Notice of appeal – FRAP 4(b)

■ Advise client of right to appeal and ascertain whether client wants to appeal – For AFPDs, election forms (when feasible) are a great help to appellate attorneys – If client waived right to appeal in a plea agreement, inform appeal would arguably breach plea agreement (but still file NOA if client so instructs) – Explain appeal is not a do over; just corrects legal errors and case usually goes back to the same district judge for further proceedings ■ NOA must be filed within 14 days of entry of judgment or government’s NOA – Filing after court announces decision and before entry of judgment is okay ■ For CJA attorneys, file NOA before filing motion to withdraw ■ If miss the 14-day deadline, can file with the district court a motion for excusable neglect based on good cause for an additional 30 days

5C Website – a great resource

■ Check the website http://www.ca5.uscourts.gov/ for helpful info, such as: – Forms & guides – Flow chart of 5C cases – Federal Rules of Appellate Procedure with 5C Rules – Record citation rules – Has links to Pacer and CM/ECF – Under “Utilities” in ECF, can:

■ Access the electronic record on appeal ■ Access brief templates ■ Check PDF of brief for compliance

– Oral argument info for upcoming arguments, and recordings of past ones

Appellate timeline

■ Court reporter typically has 30 days to complete transcript (without extensions) – FRAP 11 ■ District court clerk has to ask for an extension if can’t forward record within 15 days

• f transcripts or NOA (whichever is later); 5C clerk can grant extension up to 45

days, then extensions get decided by a judge – 5th Cir. R. 11.3 ■ Once the electronic record on appeal is ready, will get briefing notice with caption, instructions, and deadline ■ FRAP 31 deadlines: – Appellant’s opening brief – 40 days after briefing notice – Appellee’s response brief – 30 days after appellant’s brief served – Appellant’s reply brief – 21 days after appellee’s brief served (at least 7 days before argument ■ As of June 2019, median time from filing of NOA to a 5C decision was 9.1 months

Getting case started in the 5C

■ Within 14 days of filing NOA: – File notice of appearance – FRAP 12(c) – File transcript order form in district court and with 5C, instructions on 2nd page:

Getting case started in the 5C

■ Review transcripts for redactions: – Social Security or taxpayer identification numbers to the last four digits – Dates of birth to the year – Names of minor children to the initials – Financial account numbers to the last four digits – Home addresses to the city and state ■ File redaction request within 21 days of the transcript being filed (deadlines listed in CM/ECF docket text) ■ If portions or entire transcript need to be sealed, file motion to seal or redact – Otherwise, transcript available to public 90 days after its filed ■ When reviewing transcripts, flag issues such as references to other hearings or exhibits to make sure those become part of the record

Getting case started in the 5C

■ Opening letter to client explaining appellate process – Locate client through BOP Find an Inmate or U.S. Marshals ■ Reach out to trial counsel to get a sense of case (and client) ■ Speak with client to find out why he/she is appealing, explain appeal process, and (eventually) inform about issue(s) that will be raised (or that it will be an Anders) – This BOP website with counselor emails can help arrange phone calls – If still having trouble, reach out to BOP regional counsel for that facility

■ See pages 53-54 of this March 2019 BOP Legal Resource Guide

Got the briefing notice – what next?

■ Access the EROA (sometimes need to ask district clerk for access) ■ Check that record is complete: – Sealed documents?  file motion to view – Missing exhibits?  contact clerk and parties

■ Determine if need to file a motion to supplement the record ■ If seek to supplement the record with something that should be sealed, ask for it to be sealed in the motion to supplement

■ Review entire record to identify possible issues to research and ultimately raise ■ If client wants to withdraw the appeal, file motion to withdraw with client’s signed withdrawal form attached

Extensions

■ If need extension, file request at least 7 days before deadline – see 5th Cir. R. 31.4.3 – Level 1: 1-30 days from original deadline, by letter or (if unopposed) by phone – Level 2: more than 30 days, must be done by motion; be detailed about reason for delay (e.g., list cases and types of proceedings that have kept you busy) – If client to be released within 24 months, likely will need to file motion and extension may be denied – Extensions for reply briefs are disfavored (but might get 7 days) ■ Ask Government for non-opposition to extension requests (and any other motion) – Joseph Gay is the chief of appeals for the USAO of the WDTX – For simple issues, reach out to AUSA paralegals:

■ Susan.Oneal@usdoj.gov ■ Amber.Glascock@usdoj.gov ■ Norma.Olivas2@usdoj.gov

Opening brief

■ Resources for contents and format of brief: – FRAP 28, 32 – Brief template in the Utilities tab of ECF – 5C Practitioners Guide ■ Resources for contents of record excerpts: – FRAP 30 – Note: there are mandatory and optional contents, see 5th Cir. R. 30.1.4, 30.1.5 ■ Do you need to file a motion to expedite appeal? – Consider doing so for clients with short sentences or who would be looking at short sentences (or no conviction) if you win the appeal – Typically, we give the government its 30 days to respond (but no extensions) – Best not to have asked for any extensions yourself ■ Do you need to file a motion to seal the brief, record excerpts, or entire case? ■ Remember the certificate of compliance for briefs and motions! – See FRAP 32(g), Form 6

Anders brief

■ If no nonfrivolous issue, prepare an Anders brief and a motion to withdraw – Anders v. Cal., 386 U.S. 738 (1967); US v. Flores, 632 F.3d 229 (5C 2011) – Resources: 5C’s Anders Checklist and Anders Guide ■ Be sure to send client copies of the brief and motion; ideally speak to client as well ■ If the client does not read English, explain to client in a language (s)he understands: – 1) the substance of the brief; – 2) the client’s right to oppose it or seek new counsel; and – 3) the likelihood that the brief could result in dismissal of the appeal. – And include that information in the certificate of service – See US v. Moreno-Torres, 768 F.3d 439 (5C 2014) ■ Client typically has 30 days to respond – During coronatimes, 5C ordered deadlines for pro se filers extended by 30 days

Paper copies

After getting the resend notice from the 5C: ■ During normal times: – To the 5C: 7 copies of briefs (opening and reply) and 4 copies of excerpts

■ 5th Cir. R. 30.1.2, 31.1

– To the Government: none ■ During coronatimes: – To the 5C: none unless directed by the Court

■ 5th Cir. General Docket No. 2020-3

– To the Government: none

Oral argument

■ 12% of cases get oral argument ■ Typically, cases usually calendared 60 days in advance ■ Calendared for a specific date and courtroom 30 days in advance – Keep eye out for email from Shirley Engelhardt to complete oral argument form ■ During coronatimes, no in-person arguments before November – Some VTC arguments ■ Preparation: moot (FPD office can assist), listen to arguments, research panel’s decisions – Can find out panel a week before argument on website

You won – what next?

■ Notify client and trial counsel (if different than you) ■ Mandate will issue 7 days after petition for rehearing expires (usually 21 days after judgment) or 7 days after an order denying petition – FRAP 41 – Mandate is a certified copy of the judgment, a copy of the court’s opinion, if any, and any direction about costs – 5C opinion will get docketed in district court case

You lost – what next?

■ Notify client of decision and of: – Petition for rehearing deadline (and whether you intend to file one)

■ 14 days from entry of judgment – FRAP 40(a)(1)

– Petition for writ of certiorari deadline (and deadline to inform you of client’s desire to file one)

■ Typically 90 days from entry of judgment – Sup. Ct. R. 13.1 ■ But during coronatimes, extended to 150 days – Miscellaneous Order, 589 U.S. __ (Mar. 19, 2020)

■ If client wants a WOC, but filing one would be futile, file motion suggesting futility asking to be withdrawn – This allows the client to file WOC on own – See Sup. Ct. R. 10; 5th Cir. CJA Plan § 6, ¶ 4 (rev. Apr. 2009)

Resources

■ Timothy Crooks & Judy Madewell, Preserving Error: Making Sure You Get Your Second Chance on Appeal (Oct. 27, 2016), https://mow.fd.org/sites/mow.fd.org/files/training/DFCC2016/Crooks/Preserving%20Er ror%20--%20October%202016.pdf ■ 5C website: http://www.ca5.uscourts.gov/ – 5C Clerk’s Office – (504) 310-7700; contact list – Case Budgeting Attorney Margaret Alverson – 504-310-7799, margaret_alverson@ca5.uscourts.gov, http://www.lb5.uscourts.gov/CJA2/CaseBudgeting/ ■ Our office – 210-472-6700 (San Antonio) – Mary Perfecto, Secretary to the Defender – Monica Saenz, Legal Assistant – Appellate attorneys: Judy Madewell, Brad Bogan, Kristin Davidson (Austin), Kristin Kimmelman, Laura Spindler ■ Other CJA attorneys

QUESTIONS?

Kristin_Kimmelman@fd.org; 210-472-6700 x2087