Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10
BLUMBERG & ASSOCIATES

Bruce E. Blumberg
BLUMBERG & ASSOCIATES
_____________________

45 West Jefferson, Suite 210 Phoenix, Arizona 85003
Office: (602) 277-6180 Fax: (602) 271- 4119

Attorney for Defendant Arizona State Bar Number 010779

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. MARVIN WILLIAMS, Defendant

11
45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

) Case No: CR04-0381-PHX-JAT ) ) REQUEST FOR RECOMMENDATION ) TO THE BUREAU OF PRISONS ) ) ) ) ) )

COMES NOW, Defendant, Marvin Williams, by and through undersigned counsel, and respectfully requests that this Honorable Court recommend that the Bureau of Prisons house Mr. Williams in Phoenix, Arizona during his incarceration. Mr. Williams was sentenced on November 22, 2005, before this Court to a term of 63 months. Mr. Williams has children in the Phoenix area as well as an ill and disabled mother who has great difficulty moving around and traveling. Mr. Williams' placement outside of the Phoenix area would create great hardship for his ailing mother and children to maintain visits with him. RESPECTFULLY SUBMITTED, this 30 day of November, 2005.
th

BLUMBERG & ASSOCIATES

By:

s/ Bruce E. Blumberg

Case 2:04-cr-00381-JAT

Document 134

Filed 11/30/2005

Page 1 of 2

1 2 3 4 5 6 7 8 9 10
BLUMBERG & ASSOCIATES

CERTIFICATE OF SERVICE
I hereby certify that on this date, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Timothy Duax and the Honorable James A. Teilborg.

11
45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Case 2:04-cr-00381-JAT

Document 134

Filed 11/30/2005

Page 2 of 2