UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA





UNITED STATES OF AMERICA :

:

v. : Crim. No. xxxxxxxxx(JR) :

xxxxxxxxxxxxxxxxxxx :

:

_____________________________:



MOTION FOR TEMPORARY LEAVE

TO TRAVEL OUTSIDE THE WASHINGTON, D.C. AREA

xxxxxxxxx, defendant, through undersigned counsel, hereby requests the court to temporarily modify his release conditions in order that he may travel to be with relatives during In support of this request, Mr. xxxxxxxxxx states:

1. He has been charged with unlawful possession of a firearm by a convicted felon, and unlawful possession of ammunition by a convicted felon. He was arraigned on this offense on December 2, 1996. Motions hearings were held on February 10, 1997 and continued to May 1, 1997. Mr. xxxxxxxxxx was released on his personal recognizance, and is presently awaiting trial.

2. Mr. xxxxxxxxxx requests permission to travel with his family to Hampton, Virginia, during the Labor Day weekend, to visit his relatives. He requests travel time from Thursday August 28, 1997 to Tuesday September 2, 1997.

3. Mr. xxxxxxxxxx is in compliance with all the release conditions set by the court, and reports regularly and on time to the Heightened Supervision Program (HSP).

WHEREFORE, for the reasons stated above, defendant requests permission to travel for the Labor Day weekend.

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 Temporary Leave To Travel Outside the Washington, D.C. area, was transmitted by facsimile and mailed, first class, postage prepaid, to Mark Gellar, Assistant United States Attorney, 555 Fourth Street NW, Washington, DC 20001, this 20th day of August 1997.













___________________________

Valencia Rainey



UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA





UNITED STATES Of AMERICA :

:

v. : Criminal No. 9x-xxxxx(JR) :

MICHAEL J. xxxxxxxxxx :

:

______________________________:





O R D E R



Upon consideration of defendant's request for a temporary leave to travel outside the Washington, D.C. area, it is this _____day of August 1997,

ORDERED, that Mr. Davis be allowed to travel to Hampton, Virginia, to visit family during the Labor Day holiday. This travel is limited to 8:00 a.m. Thursday, August 28, 1997, to 8 p.m. Tuesday, September 2, 1997.

James Robertson

United States District Judge





Copies to:



Michael J. xxxxxxxxxx

xxxxxxxxxxxxxxxxxxx

Washington, D.C. 20032



Valencia Rainey

Assistant Federal Public Defender

625 Indiana Avenue, N.W.

Suite 550

Washington, D.C. 20004



Mark Gellar

Assistant United States Attorney

555 4th Street, N.W.

Washington, D.C. 20001