11/24/2009 47 MOTION to Modify Conditions of Release by Rufus Paul Harris. (Manchel, Howard) (Entered: 11/24/2009)
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RUFUS PAUL HARRIS’ MOTION TO MODIFY THE TERMS OF HIS PRETRIAL RELEASE
Comes now Rufus Paul Harris, Defendant herein, and moves this Court to modify his conditions of pretrial release in the following respects:
1. Defendant seeks to return to his residence at ,_______ Oklahoma City, Oklahoma, 73162. Currently, Mr. Harris is under the condition that he reside in this district and presently he is living with his wife and two daughters in Room xxx, Woodberry Inn & Suites, 1318 Martha Berry Blvd., Hwy. 27 North, Rome, Georgia. Defendant selected the Rome area because his wife’s family lives in nearby Adairsville.
2. Defendant seeks this change because he has been unable to find affordable housing (compared to Oklahoma City) in the area and so that his two minor daughters, ages 7 and 13 can return to their friends and respective schools.
3. Defendant states that he hoped to find a suitable rental within a suitable school district, but upon trying to move his family to Georgia additional costs, including moving expenses, utility deposits, and security deposits are incurred. All expenses that Defendant is unable to afford. In addition there are hardships on his children who are leaving one school district for another.
4. One of Defendant’s pretrial conditions is that he seek employment. At this time Mr. Harris is unemployed. If allowed to return to Oklahoma City he can work for his landlord rehabbing rental homes; also he has been offered a job by a neighbor doing tree work. Defendant believes because of his social contacts getting a job will be easier.
5. Finally, the Government does not oppose this request to return to Oklahoma. Defendant understands that the Government seeks to impose certain conditions not now in place so a hearing is necessary.
WHEREFORE, Defendant Harris asks this Court to conduct an inquiry into the conditions of his pretrial release, and allow him to return to his home in Oklahoma City.
Respectfully submitted,
Howard J. Manchel
Howard J. Manchel
Ga. Bar No. 468550
Attorney for Rufus Paul Harris
729 Piedmont Avenue
Atlanta, Georgia 30308
404-522-1701 |
