Free Motion for Release from Custody - District Court of Delaware - Delaware

Case 1:07-cr-00171-JJF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANGELA JONES, Defendant.

: : : : : : : : :

Criminal Action No. 07-171-JJF

MOTION FOR TEMPORARY RELEASE ON RECOGNIZANCE BAIL TO ATTEND SISTER'S FUNERAL Defendant, Angela Jones, by and through her undersigned counsel, Eleni Kousoulis, hereby moves the Court for an Order permitting the defendant to be released on recognizance bail, with Tamar Daniels acting as custodian, for 50 hours to attend her sister's funeral. In support of this motion, the Defendant submits as follows: 1. On December 13, 2007, a four count Indictment was returned against Angela Jones

charging her with Possession of a Firearm by Felon, in violation of Title 18, U.S.C. §§ 922(g)(1) and 924(a)(2); Making a False Statement to a Firearm's Dealer with the Intent to Deceive, in violation of Title 18, U.S.C. §§ 922(a)(6) and 924(a)(2); Making a False Statement with Respect to Information to be Kept by a Firearm's Dealer, in violation of Title 18, U.S.C. § 924(a)(1); and Knowingly Possessing Cocaine Base, in violation of Title 21, U.S.C. § 844(a). 2. Following a Detention Hearing on November 21, 2007, Ms. Jones was ordered

detained pending trial. Ms. Jones is currently detained at the Baylor Women's Correctional Institution.

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3.

On January 19, 2008, Ms. Jones' sister, Anita Jones, passed away. The funeral for

Anita Jones will be held on Friday, January 25, 2008 at 2:00 p.m., in Griffin, GA. See Exhibit A. 4. Ms. Jones would very much like to attend her sister's funeral, as expressed by Ms.

Jones in her letter dated January 21, 2008. See Exhibit B.1 5. Ms. Jones respect fully requests to be relea s ed

on recognizance bail, with Tamar Daniels acting as custodian, for 50 hours (leaving Thursday morning, January 24, 2008, and returning Saturday afternoon, January 26, 2008) to allow her to travel to Georgia to attend her sister's funeral. 6. While in Georgia, Ms. Jones will stay with her mother, Susie Nettles, at 1445 Upland

Drive, Griffin, GA 30223. 7. Ms. Jones will contact pre-trial services (a) when she arrives in Georgia, and (b)

when she leaves Georgia to return to Delaware. 8. Assistant United States Attorney, Shawn Weede, the attorney handling this case for

the government, does not oppose the defendant's motion, making this motion unopposed. WHEREFORE, it is respectfully requested that Defendant, Angela Jones, be granted temporary release for 50 hours to attend her sister's funeral in Griffin, GA.

Respectfully submitted, /s/ Eleni Kousoulis, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected] Attorney for Defendant Angela Jones Dated: January 23, 2008 Letters from Angela Jones' mother, Susie Nettles, and her father, Frank Jones, are also attached to this motion as "Exhibit C". 2
1

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. ANGELA JONES, Defendant.

: : : : : Criminal Action No. 07-171-JJF : : : : ORDER

Having considered Defendant Angela Jones' Motion for Temporary Release on Recognizance Bail to Attend Sister's Funeral, IT IS HEREBY ORDERED this of conditions: (1) Defendant, Angela Jones, shall be released at 10:00a.m. on Thursday, January 24, 2008, from the Baylor Women's Correctional Institution, in the care and custody of Tamara Daniels; (2) Defendant is to drive directly to Griffin, GA, with Tamara Daniels, and stay overnight with her mother, Susie Nettles, at 1445 Upland Drive, Griffin, GA 30223, and contact pre-trial services upon her arrival. (3) Defendant is to attend her sister, Anita Jones', funeral at 2:00 p.m. on Friday, January 25, 2008, at the Haisten McCullough Funeral Home, located at 1155 Everee Inn Road, Griffin, GA 30224; (4) Following the funeral, the defendant is to drive directly back to Delaware, and turn herself into the Baylor Women's Correctional Institution, no later than Saturday, January 26, 2008, at 12:00 p.m; the defendant will contact pre-trial services to notify them of her departure from Georgia. , 2008, that Defendant's Motion is GRANTED, with the following day

Honorable Joseph J. Farnan, Jr. United States District Court

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