Case 8:12-cr-00569-DNH Document 50 Filed 03/18/13 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE
NORTHERN DISTRICT OF NEW YORK
________________________________________
UNITED STATES OF AMERICA,
Plaintiff,
Case No.: 12-cr-569 (DNH)
v.
JAMES GRAY,
WILLIAM ROGER JOCK,
THOMAS ANGUS SQUARE,
also known as “Salt,”
ANTHONY LAUGHING, SR., and
JOSEPH HIGHT,
Defendants.
________________________________________
MOTION FOR RECONSIDERATION OF ORDER OF REFERRAL
DEFENDANTS, JAMES GRAY, WILLIAM ROGER JOCK, and THOMAS ANGUS
SQUARE, respectfully request the Court to reconsider its Order, dated March 18, 2013, of
referral, (Doc. N. 49), and in support states as follows:
1.
In support of the Order of referral, the Court stated, “It is apparent that these three
defendants cannot be represented by the same counsel.”
2.
However, defendants Jock and Square have previously executed a waiver of
conflict of interest. See, Exhibit 1, annexed hereto.
3.
Also, on February 24, 2013, by official action of the Kanienkehaka Longhouse,
Akwesasne, kanienkeha, the undersigned was appointed, authorized, and directed to represent the
Kanienkehaka Longhouse, Akwesasne, kanienkeha, and its people who have been charged, and
may be charged, in the above referenced case. This includes defendants Gray, Jock, and Square.
See, Exhibit 2, annexed hereto.
Case 8:12-cr-00569-DNH Document 50 Filed 03/18/13 Page 2 of 2
4.
In the alternative, the Court is requested to direct a hearing be had before the
Court for the Court to question the defendants as to their choice of counsel and the waiver of any
conflict of interest.
RELIEF REQUESTED
FOR THE FOREGOING REASONS, DEFENDANTS, JAMES GRAY, WILLIAM
ROGER JOCK, and THOMAS ANGUS SQUARE, respectfully request the Court to reconsider
its Order of referral dated March 18, 2013, (Doc. No. 49).
Dated: New York, New York
March 18, 2013
Respectfully submitted,
MOORE INTERNATIONAL LAW PLLC
/s/ Scott Michael Moore
By: ________________________________
Scott Michael Moore, Esq. (Bar Roll No. 512231)
Attorneys for Defendants,
James Gray, William Roger Jock, and Thomas Angus Square
45 Rockefeller Plaza, Suite 2000
New York, New York 10111
T. (212) 332-3474
F. (212) 332-3475
E. [email protected]
CERTIFICATE OF SERVICE
I hereby certify that on the date below, I served a true copy of the annexed Instrument via
ECF electronic service to all ECF counsel of record:
Dated: New York, New York
March 18, 2013
/s/ Scott Michael Moore
________________________________
Scott Michael Moore, Esq.
2
Case 8:12-cr-00569-DNH Document 50-1 Filed 03/18/13 Page 1 of 1
MOORE INTERNATIONAL LAW PLLC
45 ROCKEFELLER PLAZA, SUITE 2000
NEW YORK, NEW YORK 10111 USA
TELEPHONE: + (212) 332-3474
FACSIMILE: + (212) 332-3475
INTERNATIONAL LEGAL MATTERS
WRITER: SCOTT MICHAEL MOORE
[email protected]
LICENSED & ADMITTED
SUPREME COURT OF THE UNITED STATES OF AMERICA
U.S. COURT OF APPEALS FOR THE FEDERAL CIRCUIT
U.S. COURT OF INTERNATIONAL TRADE
OTHER U.S. FEDERAL COURTS
STATES OF NEW YORK & MICHIGAN ONLY
LONDON COURT OF INTERNATIONAL ARBITRATION
31 December 2012
Sakoieta, a/k/a James Gray
Kanratiio a/k/a William Roger Jock
Rorahkewesare, a/k/a Thomas Square
Mens Council of the Great Law Longhouse
Kanienkehaka Kanonhsesne Mohawk Nation
Akwesasne
Re:
USA v. Gray et al, 12-cr-569, U.S. District Court, Northern District of New York
Gentlemen:
Your signature on this letter will confirm that the undersigned has explained to each of
you, as Clan representatives to the Mens Council, conflict of interest issues relating to the
undersigned providing common legal representation to you in the case known as USA v. Gray et
al, 12-cr-569, pending in the United States District Court for the Northern District of New York,
and your waiver of any conflict of interest objections.
Very Truly Yours,
MOORE INTERNATIONAL LAW PLLC
BY: /s/ Scott Michael Moore
Scott Michael Moore
Attorney at Law
puvzzit
Dated:
Sakoieta, a/k/a James Gray,
Turtle Clan Representative
a ,eddr/er J.:(
k, Dated:
Kiehwill(Pc Kartratile a/k/a William Ro
Bear Clan Representative
0
Dated:
Rer-ohkewesare,
a/k/a
Thomas
Square,
44trez..0a) /sere
Wolf Clan Representative
,
o2
/3
Case 8:12-cr-00569-DNH Document 50-2 Filed 03/18/13 Page 1 of 1
Kanienkehaka
Teharbors le Nawa ken
People of the imaghoose Ahkwesasne
MR. Scott Michael Moore, Esq., International Law PLLC, 45 Rockefeller
Plaza Suite 2000 New York, New York 10111. Is hereby appointed,
authorized and directed to represent the Kanienkehaka Longhouse,
Akwesasne, kanienkeha, and its people who have been charged, and may be
charged, in the case known as USA v. GRAY et al, CASE NO.12-cr-569
United States District Court for the Northern District of New York.
Signature
Our sear
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