UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA, :
:
Plaintiff, :
:
v. : CRIM.NO. :
xxxxxxxxxxx, :
:
Defendant. :
MOTION TO TRAVEL AND CONTINUE STATUS HEARING DATE
The defendant xxxxxxxxx,through undersigned counsel, requests permission to travel to FPC Alderson, in Alderson, West Virginia, to visit his wife who is incarcerated in that facility.
In support of this Motion, he states:
1. Mr. xxxxx was convicted of bank fraud and related offenses, and is presently released on personal recognizance awaiting designation to a federal facility.
2. In July 1997, Mr. xxxxx was issued a travel pass that permitted him to travel from Washington, D.C., to the federal prison facility at Alderson, West Virginia, to visit his wife for the weekend.
3. Mr. xxxxx requests permission to continue to travel and visit with his wife on weekends until he is designated to a federal facility to begin his sentence.
4. Mr. xxxxx is in compliance with all the release conditions set by the court.
WHEREFORE, for the reasons stated above, Mr. xxxxx requests permission to travel during the month of August 1997, to visit with his wife at FPC Alderson.
Respectfully submitted,
A.J. KRAMER
FEDERAL PUBLIC DEFENDER
Valencia Rainey
Assistant Federal Public Defender 625 Indiana Avenue, N.W.,Suite 550
Washington, DC 20004
(202) 208-7500, ext. 102
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing Motion For Permission To Travel Outside the Washington, D.C. area for Spousal Visits was transmitted by facsimile and mailed, first class, postage prepaid, to Judith Kozlowski, Assistant United States Attorney, 555 Fourth Street NW, Washington, DC 20001, this 20th day of April 1997.
___________________________
Valencia Rainey
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES Of AMERICA :
:
v. : Criminal No. 96-136(JR) :
NATHANIEL xxxxx :
______________________________:
O R D E R
Upon consideration of Nathaniel xxxxx's request for leave to travel outside the Washington, D.C. area, it is this _____day of August 1997,
ORDERED, that the defendant be granted travel privilege to visit his wife in Alderson, West Virginia, on weekends beginning August 23, 1997. This order will terminate upon notice that Mr. xxxxx has been designated by the United States Bureau of Prisons.
James Robertson
United States District Judge
Copies to:
xxxxxxxxxxxx xxxxx
xxxxxxxxxxx
Washington, D.C. 20001
Valencia Rainey
Assistant Federal Public Defender
625 Indiana Avenue, N.W.
Suite 550
Washington, D.C. 20004
Judith Kozlowski
Assistant United States Attorney
555 4th Street, N.W.
Washington, D.C. 20001
MOTION TO CONTINUE STATUS HEARING
Undersigned counsel respectfully moves the court to continue the status hearing which is presently scheduled for May 6, 1997, and as grounds, shows the court:
1. On April 8, 1997, a grand jury returned an indictment charging Mr. xxxx with assault on a federal officer, in violation of 18 U.S.C. § 111(a) (Count One); threatening to injure a person, in violation of 22 D.C.C. § 2307 (Count Two); and obstruction of justice, in violation of 22 D.C.C. § 722(a)(6) (Count Three). These charges are based on an alleged incident occurring March 27, 1997.
2. On April 17, 1997, Mr. xxxxxx appeared before this Court and entered a not guilty plea to the above-mentioned charges. At that time, the Court scheduled a status hearing for May 6, 1997. Also at that time, defense counsel filed a Motion for Reconsideration of the Pretrial Detention Order. The government filed its Opposition approximately April 18, 1997. Undersigned counsel has not yet received the Court's ruling on this pending motion.
3. On April 21, 1997, undersigned counsel received discovery items from Assistant United States Attorney John Beasley, Jr. According to the government, additional discovery is to be provided the week of April 28, 1997.
4. Undersigned counsel respectfully requests a continuance of the May 6, 1997 status hearing to a date convenient with this Court after May 12, 1997. Undersigned counsel is scheduled to be out of the District from April 28, 1997 through May 9, 1997 on annual leave.
5. John Beasley, Jr., Esq., the Assistant United States Attorney assigned to this case, has advised undersigned counsel that he does not oppose this request for continuance. AUSA Beasley also advised counsel that he would be out of the office the week of April 21, 1997.
Therefore, undersigned counsel respectfully requests that the status hearing scheduled for May 6, 1997 be continued to a date after May 12, 1997 that is convenient with this Court.
Respectfully submitted,
A. J. KRAMER
FEDERAL PUBLIC DEFENDER
Teresa Alva
Assistant Federal Public Defender On Behalf of Tyrone B. xxxxxx 625 Indiana Avenue, N.W. Washington, D.C. 20004
(202) 208-7500
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA )
)
v. ) CRIM. NO. 97-0138-O1 (NJH) )
TYRONE B. xxxxxx )
Defendant. )
)
O R D E R
Upon consideration of Mr. xxxxxx's Motion to Continue the Status Hearing, and the entire record in this matter, it is this _____________ day of ____________ 1997, hereby
ORDERED that Mr. xxxxxx's motion is granted; and it is further
ORDERED that this matter be scheduled for a status conference on _____________________________________ at __________a.m./p.m.
THE HONORABLE NORMA HOLLOWAY JOHNSON
UNITED STATES DISTRICT COURT JUDGE
Copies to:
Teresa Alva
Assistant Federal Public Defender
625 Indiana Avenue, N.W.
Suite 550
Washington, D.C. 20004
John Beasley, Jr.
Assistant U.S. Attorney
Judiciary Center Building
555 4th Street, N.W.
Washington, D.C. 20001
CERTIFICATE OF SERVICE
I, Teresa Alva, Assistant Federal Public Defender, hereby certify that a copy of Mr. xxxxxx's Motion to Continue the Status Hearing was served by first- class mail, postage prepaid, upon:
John Beasley, Jr., Esquire
Office of the United States Attorney for the
District of Columbia
555 4th Street, N.W.
Washington, D.C. 20001
Teresa Alva
Assistant Federal Public Defender