DEFENDANT, by and through undersigned counsel, respectfully requests this Honorable Court to enter an Order allowing Defendant to be furloughed from the Washington DC Detention Center. As grounds for this Motion, Defendant states as follows:
- Defendant was charged by Information in the above-captioned case with one count of Unlawful Reception of Cable TV Services, and one count of Trespass and Larceny with Relation to Utility Fixture.
- On February 2, 2010, Defendant entered a plea of no contest to the above-referenced charges and received a probationary sentence of one year.
- On September 21, 2010, Defendant entered a plea of no contest to a charge of Violation of Probation. Defendant received a jail sentence of 180 days, with a sentence credit of twenty-three days. Defendant was immediately remanded to the custody of the Washington DC Sheriff.
- On January 5, 2011, during the course of Defendant’s incarceration, Defendant’s wife died of complications associated with pneumonia. A funeral service has been scheduled for January 22, 2011.
- Defendant requests to be furloughed from his present jail sentence for no more than five days, commencing on January 19, 2011, to attend to his children and attend the funeral service.
- Defendant acknowledges that, if this request for furlough is granted, his term of incarceration will be tolled for as many days as his furlough is effective.
- Defendant further acknowledges that willful failure to return to the Washington DC Detention Center as ordered by this Court may result in additional criminal charges.
WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order granting this Motion for Furlough.