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