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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA


MIAMI DIVSION

CASE NO: 06-20395-CR-UNGARO/Simonton

UNITED STATES OF AMERICA,

Plaintiff,
vs.

DORIS TRAPP,

Defendant.
/

MOTION TO SUPPLEMENT RECORD ON APPEAL

COMES NOW, the Defendant/Appellant, DORIS TRAPP, by and through her

undersigned attorney and files this motion to supplement the record on appeal in this cause and

as grounds would state:

1. Appellant filed her Notice of Appeal in this cause on July 31, 2009. [DE 402]

Appellant appeals the sentence imposed as a result of her violation of supervised release.

2. That part of Defendants/Appellants appeal will involve the Pronouncement and

Judgment in a Criminal Case entered in the underlying substantive case, to wit: 08-20650-CR-

COOKE. It was this substantive case that resulted in the Violation of Supervised Release in the

instant matter. There was reference in the Pronouncement and Judgment in a Criminal Case in

08-20650-CR-COOKE to the sentence to be imposed in this case.

3. The transcript of the Sentencing Hearing conducted in Case Number: 08-20650-CR-

COOKE [DE 421] on April 1, 2009 and the Judgment in a Criminal Case in that matter [DE 422]

will be required for a complete record in this cause.


4. Undersigned counsel has contacted Michael Sofia, Assistant United States Attorney

who handled the sentencing hearing in the above styled matter and he does not object to this

request to Supplement the Record.

WHEREFORE, Appellant respectfully requests this Honorable Court to enter an order

directing the clerk of the district court to supplement the record on appeal with the transcript of

the sentencing hearing held on April 1, 2009 in case number 08-20650-CR-COOKE [DE 421]

and the Judgment in a Criminal Case entered on April 3, 2009 in case number 08-20650-CR-

COOKE [DE 422].

JONATHAN S. FRIEDMAN, P.A.


ONE EAST BROWARD BLVD.
SUITE 925
WACHOVIA BANK TOWER
FORT LAUDERDALE, FLORIDA 33301
TELEPHONE (954) 713-2820
FACSIMILE (954) 713-2894

_/S/ Jonathan S. Friedman_____


JONATHAN S. FRIEDMAN, ESQ.
FLORIDA BAR NUMBER: 0973297
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 24, 2009, the undersigned attorney electronically

filed the foregoing document with the Clerk of the Court, the United States Attorney's Office and

other counsel of record, if any, using CM/ECF and has served same via U.S. Mail to those

counsel(s) or individuals, if any, who are not authorized to receive electronically Notice of

Electronic Filing.

_/S/ Jonathan S. Friedman_____


JONATHAN S. FRIEDMAN, ESQ.
FLORIDA BAR NUMBER: 0973297