Question juridique clé
Whether the federal criminal appeal was filed within the statutory time limit.
Solution extraite
No. The appeal period ran from service on the appellant's former counsel, and the filing of 4 March 2011 was late.
Motifs extraits
The decisive service date was 28 January 2011, when the challenged decision was delivered to counsel. Personal receipt by the appellant later did not affect the start of the federal deadline. The last timely filing date was 28 February 2011.