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UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

United States of America

v. CR. 07--cr-00189-GZS-1

Daniel Riley

MOTION TO EXCEED

NOW COMES Sven D. Wiberg, appointed standby counsel for the accused, and
respectfully requests that this Honorable Court authorize payment of fees in excess of the
statutory maximum, since payment has already been approved for predecessor counsel
and hours expended by the undersigned will result in voucher requests in excess of the
maximum.

In support of this motion the following is stated:

1. The undersigned was appointed as standby counsel for Mr. Riley after the
Court approved the withdrawal of Mark Howard, Esquire on October 25, 2007.
2. This case is a complex case. Discovery has been voluminous and there have
been nearly 200 docket entries since the undersigned was appointed under the CJA.
Moreover, there are a total of 269 documents or orders in the Court’s file to date.
3. Predecessor counsel, Mr. Howard, has submitted his final voucher, in the
in the amount of $5,050.46, which amount has been approved for payment. The
undersigned believes that he has expended as many or more hours of representation in this
case since being appointed.
4. At least one other appointed counsel has submitted a substantial voucher in
this case.
5. In light of the foregoing, the undersigned anticipates that the
the total counsel fees for representation of Mr. Riley will exceed the statutory maximums.
6. Due to the nature of this motion, counsel submits that the Government does not
have standing on this issue and assent is not necessary.
WHEREFORE, counsel asks this Court to grant this motion and authorize payment
in excess of the statutory maximums.

Respectfully submitted,

Dated: 2/24/08 By: /s/ Sven Wiberg


Sven Wiberg
N.H. Bar #8238
Wiberg Law Office, PLLC
2456 Lafayette Rd., Suite 7
Portsmouth, N.H. 03801
(603) 686-5454

CERTIFICATE PURSUANT TO RULE 7.1

Due to the nature of this motion, counsel believes that neither a memorandum of law or
assent by the Government is necessary.

/s/ Sven Wiberg


Sven D. Wiberg

CERTIFICATE OF SERVICE

I, Sven Wiberg, hereby certify that a true copy of the foregoing Motion will be
served on all parties by ECF filing on this 24 th day of February, 2008.
/s/ Sven Wiberg
Sven D. Wiberg

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