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Waiver of right of respondent United - Main Document

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Waiver of ri...
The Government hereby waives its right to file a response to the petition in this case, unless requested to do so by the Court.
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Petition for a writ of certiorari and - Motion for Leave to Proceed in Forma Pau

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Petition for...
Argemiro Zapata-Castro, AKA Sealed Defendant 1, respectfully request leave to file the attached petition for a writ of certiorari without prepayment of costs and to proceed in forma pauperis.
On November 30, 2018, the United States District Court for the Southern District of New York found Petitioner Antonius indigent and appointed Jill R. Shellow, Esquire, counsel of record before this Court, pursuant to the Criminal Justice Act of 1964, as amended, 18 U.S.C. § 3006A (“CJA”).
Pursuant to the Second Circuit Court of Appeals Local Rule 4.1(a), Ms. Shellow’s CJA appointment was
A copy of the Notice of Appointment of CJA Counsel and Order of the Court of Appeals are attached.
WHEREFORE, Petitioners move this Court for leave to file the attached petition for a writ of certiorari without prepayment of costs and to proceed in forma pauperis.
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Petition for a writ of certiorari and - Proof of Service

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Petition for...
I, Melissa Pickett, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for Petitioners.
That on the 11th day of March, 2024, I served the within Motion for Leave to Proceed in Forma Pauperis as to Shervington Lovell; Motion for Leave to Proceed in Forma Pauperis as to Steven Antonius and Argemiro Zapata- Castro; and Petition for a Writ of Certiorari in the above-captioned matter upon: Elizabeth Prelogar Solicitor General United States Department of Justice 950 Pennsylvania Avenue, N.W.
That on the same date as above, I sent to this Court eleven copies of the within Motion for Leave to Proceed in Forma Pauperis as to Shervington Lovell; Motion for Leave to Proceed in Forma Pauperis as to Steven Antonius and Argemiro Zapata-Castro; and Petition for a Writ of Certiorari through the United States Postal Service by Express Mail, postage prepaid.
I declare under penalty of perjury that the foregoing is true and correct.
Notary Public State of New York No. 01BR6004935 Qualified in Richmond County Commission Expires March 30, 2026 #326542
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Petition for a writ of certiorari and - Motion for Leave to Proceed in Forma Pau

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Petition for...
This proceeding is a petition for a writ of certiorari to review the judgment and opinion of the United States Court of Appeals for the Second Circuit, filed on July 10, 2023, affirming the petitioner's convictions and sentence in a federal criminal case.
At petitioner's request, undersigned counsel has prepared the attached petition for minimal fee, hoping for r L mbursement of direct expenses.
Petitioner's personal financial condition has only worsened in the yr ars since his arrest, and he is therefore unable to pay any of the costs or fees associated with this petition.
my motion to proceec ·n Jonna pa:uperis, I state thaL because of my poverty I am unable to pay the costs of this case or to give security therefor; and I believe I am entitled to redress.
$ o .ac::, Employment Self-employment Income from real property (such as rental income) Interest and dividends Gifts Alimony Child Support Retirement (such as social security, pensions, annuities, insurance) Disability (such as social security, insurance payments) Unemployment payments Public-assistance (such as welfare) Other (specify): $ o .oo_
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Petition for a writ of certiorari and - Petition

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Petition for...
Moreover, none ever entered the United States1 or communicated with anyone in the United States as part of their plan. None of the Petitioners’ actions took place in or had any contact with the United States. Pet. App.
3 None of Petitioners was on board.
2 None of the Appellants were on board.
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USA v. Vasquez-Drew

Docket 1:19-cr-00091, New York Southern District Court (Feb. 12, 2019)
Judge Denise L. Cote, presiding, Magistrate Judge Robyn F. Tarnofsky
DivisionFoley Square
FlagsECF
DeadlineThe parties shall be prepared to address the October 17, 2025 trial date and the May 16, 2025 (Status Conference set for 12/18/2024 at 03:30 PM in Courtroom 18B, 500 Pearl Street
Defendant Percy Arturo Vasquez-Drew
Defendant Osvaldo Londono-Vanegas
Defendant Victor Rojas-Bascope
...
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, Argemiro Zapata-Castro, aka Sealed Defendant 1, Applicants v. United States, 23A619, Application to ex...
At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 12th day of October, two thousand twenty-three.
United States of America, Appellee,
Appellant, Shervington Lovell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc.
The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc.
Catherine O'Hagan Wolfe, Clerk
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Application to extend the time to file a - Proof of Service

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, Argemiro Zapata-Castro, aka Sealed Defendant 1, Applicants v. United States, 23A619, Application to ex...
UNITED STATES OF AMERICA, Respondent.
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Application to extend the time to file a - Main Document

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, Argemiro Zapata-Castro, aka Sealed Defendant 1, Applicants v. United States, 23A619, Application to ex...
None of the applicants were United States citizens, entered the United States, or used any instrumentality connected to the United States.
None of the applicants were on board. b.
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, Argemiro Zapata-Castro, aka Sealed Defendant 1, Applicants v. United States, 23A619, Application to ex...
2 None of the of their efforts to further the conspiracy— Appellants were on board. could be prosecuted under the MDLEA.
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, Argemiro Zapata-Castro, aka Sealed Defendant 1, Applicants v. United States, 23A619, Application to ex...
Based on this discussion in Medellin, the timing and location of the vessel’s interdiction, the nationality of the vessel’s captain, and the vessel’s appearance, the Government alleges that the seized vessel contained a portion of the cocaine that Defendants Zapata-Castro, Lovell, Antonius, and Cardona-Cardona had conspired to transport from Guyana to the Netherlands.
Accordingly, in light of the conspiracy’s nexus to United States interests in eliminating drug trafficking on the high seas, and the fair warning we ascribe to those that participate in such conspiracies, we conclude that due process was not offended by defendants’ MDLEA prosecutions.
[6] [7]Alarcon Sanchez and Van Der End also make clear that there is no due process requirement that Cardona-Cardona and the other alleged co-conspirators here understood that their plan to transport huge amounts of cocaine from South America to the Netherlands would subject them to criminal liability in the United States.
the in Alarcon Sanchez, as Here, is Government’s MDLEA prosecution “neither arbitrary nor fundamentally unfair.” In conspiring to commit the alleged international drug trafficking crime – which involved transporting 1400 kilograms of cocaine across two continents, and at enormous expense – Defendants struck at “the very U.S. interests animating the
“[I]n light of the conspiracy’s nexus to United States interests in eliminating drug trafficking on the high seas, and the fair warning [the Second Circuit] ascribe[s] to those that participate in such conspiracies, [this Court] concludes that due process [is] not offended by [D]efendants’ MDLEA prosecutions.” Id.
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Application...
At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 12th day of October, two thousand twenty-three.
United States of America, Appellee,
Appellant, Shervington Lovell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc.
The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc.
Catherine O'Hagan Wolfe, Clerk
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Application...
Based on this discussion in Medellin, the timing and location of the vessel’s interdiction, the nationality of the vessel’s captain, and the vessel’s appearance, the Government alleges that the seized vessel contained a portion of the cocaine that Defendants Zapata-Castro, Lovell, Antonius, and Cardona-Cardona had conspired to transport from Guyana to the Netherlands.
Accordingly, in light of the conspiracy’s nexus to United States interests in eliminating drug trafficking on the high seas, and the fair warning we ascribe to those that participate in such conspiracies, we conclude that due process was not offended by defendants’ MDLEA prosecutions.
[6] [7]Alarcon Sanchez and Van Der End also make clear that there is no due process requirement that Cardona-Cardona and the other alleged co-conspirators here understood that their plan to transport huge amounts of cocaine from South America to the Netherlands would subject them to criminal liability in the United States.
the in Alarcon Sanchez, as Here, is Government’s MDLEA prosecution “neither arbitrary nor fundamentally unfair.” In conspiring to commit the alleged international drug trafficking crime – which involved transporting 1400 kilograms of cocaine across two continents, and at enormous expense – Defendants struck at “the very U.S. interests animating the
“[I]n light of the conspiracy’s nexus to United States interests in eliminating drug trafficking on the high seas, and the fair warning [the Second Circuit] ascribe[s] to those that participate in such conspiracies, [this Court] concludes that due process [is] not offended by [D]efendants’ MDLEA prosecutions.” Id.
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Application to extend the time to file a - Lower Court Orders-Opinions

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Application...
2 None of the of their efforts to further the conspiracy— Appellants were on board. could be prosecuted under the MDLEA.
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Application to extend the time to file a - Main Document

Document Steven Antonius, aka Sealed Defendant 1, Shervington Lovell, aka Sealed Defendant 1, and Argemiro Zapata-Castro, aka Sealed Defendant 1, Petitioners v. United States, 23-6971, Application...
None of the applicants were United States citizens, entered the United States, or used any instrumentality connected to the United States.
None of the applicants were on board. b.
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