UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA





UNITED STATES OF AMERICA :

:

v. : Criminal No. xxxxxxxx(JR) :

xxxxxxxxxxx :

:

________________________________:



MOTION TO REQUEST WEEKEND SOCIAL PASSES

TO VISIT WITH WIFE AND CHILDREN



xxxxxxxxxxx, through undersigned counsel, hereby requests the court to recommend that he be granted social passes to visit his wife and children on weekends, from Friday evenings to Sunday evenings. In support of this Motion, Mr. xxxxxxxxx states:

1. He pled guilty to possession of a firearm with obliterated serial number, and was sentenced to a term of imprisonment for 18 months, six months to be served imprisoned in a federal correctional institute, and the remaining 12 months to be served in a federal halfway house so that he may continue to work and support his family.

2. Mr. xxxxxxxxx is housed at Shaw II, a federal halfway house located in Washington. D.C. According to the Director of Shaw II, Mr. Michael Durant, Mr. xxxxxxxxx, immediately obtained employment, and is in compliance with all conditions related to his halfway house residence. Mr. Durant has no objection to the court's granting Mr. xxxxxxxxx the privilege of weekend visits to his family. (Please see attached Memorandum from Michael A. Durant, Director of Adult Residential Programs.)

3. Undersigned counsel contacted the Assistant United States Attorney, Ms. Odessa Vincent, and advised her of Mr. xxxxxxxxx's request. As of the filing of this motion, we have not received a response from Ms. Vincent.

WHEREFORE, for the reasons stated above, Mr. xxxxxxxxx requests that the court grant this Motion, and permit him to visit his wife and children on the weekends from Friday evenings until Sunday evenings.

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 To Request Weekend Social Passes To Visit With Wife and Children has been served upon Odessa Vincent, Assistant United States Attorney, 555 Fourth St. N.W., Washington, D.C. 20001 this 11th day of February 1999, by leaving a copy in the box designated for the Office of the United States Attorney in the Clerk's office of the United States District Court for the District of Columbia.



______________________

Valencia Rainey

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA



UNITED STATES OF AMERICA :

:

v. : Criminal No. xxxxxx(JR) :

MICHAEL J. xxxxxxxxx :

:

________________________________:



O R D E R



Upon consideration of defendant's Motion To Request Weekend Social Passes To Visit With Wife And Children, it is this _____day of February 1999,

ORDERED, that Mr. xxxxxxxxx be granted social passes to visit with his wife and children on the weekends. His visits are limited to Friday evenings until Sunday evenings on weekends.



James Robertson

United States District Judge



Copies to:



xxxxxxxxx J. xxxxxxxxx

xxxxxxxxxxxx

Washington, D.C. 20032



Valencia Rainey

Assistant Federal Public Defender

625 Indiana Avenue, N.W. Suite 550

Washington, D.C. 20004



Odessa Vincent

Assistant United States Attorney

555 4th Street, N.W.

Washington, D.C. 20001