Motion to Proceed In Forma Pauperis — Joseph D. Brown, Petitioner v. United States

NO.

IN THE UNITED STATES SUPREME COURT

TERM

JOSEPH D. BROWN,

Petitioner,

v.

UNITED STATES OF AMERICA,

Respondent.

PETITION FOR WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

Docket No. 20-6296 Below

Motion for Leave to Proceed in Forma Pauperis

The petitioner, Joseph D. Brown, asks leave to file the attached Petition for

Writ of Certiorari without prepayment of costs and to proceed in forma pauperis.

The petitioner previously has been granted leave to proceed in forma pauperis

in the following courts: United States District Court for the Eastern District of

Tennessee at Chattanooga and in the United States Court of Appeals for the Sixth

Circuit.

Petitioner’s affidavit or declaration is not attached because the Court below

appointed counsel in the current proceeding and a copy of the order of appointment

is appended hereto.

Respectfully submitted,

Paul Bersmann/ Ill

Attorney for Petitioner Joseph D. Brown

633 Chestnut Street, Suite 1620

Chattanooga, TN 37450

Telephone: 123-756-3245

Facsimile: 423-267-0126

email: pb3@epbfi.com

TN BPR # 009133

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and exact copy of the foregoing has been

served upon the Solicitor General, Department of Justice, 950 Pennsylvania Avenue,

N.W., Room 5616, Washington, D.C., 20530, and to Luke McLaurin, Assistant United

States Attorney, 800 Market Street, Knoxville, Tennessee, 37902, first class through

the U.S. Mails or by third-party delivery. AUSA McLaurin has also been served via

e-mail.

This the 22,4 day of November, 2021.

L Wenrtrom, Vas

Pau Bergmann/III '

Attorney for Petitioner Joseph D. Brown

633 Chestnut Street, Suite 1620

Chattanooga, TN 87450

Telephone: 423-756-3245

Facsimile: 423-267-0126

email: pb3@epbfi.com

TN BPR # 009133

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA

v. Case No.: 1:19-cr—00105-HSM-SKL

JOSEPH D BROWN

ORDER

The Court finds that defendant, Joseph D Brown, does not have the funds to retain an attorney of

defendant's choice and that defendant wants to be represented by counsel. As a condition of the appointment

of counsel to represent defendant, the Court reserves the right to require the defendant to repay the

government the reasonable value of the services rendered to defendant by the appointed counsel and any

expenses in connection therewith. Accordingly, it is ORDERED the following counsel will be appointed to

represent defendant:

ENTER.

s/Susan K Lee

UNITED STATES MAGISTRATE JUDGE

Case 1:19-cr-00105-TRM-SKL Document 24 Filed 01/02/20 Page 1of1 PagelD #: 42