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

Case 1:08-cr-00008-GMS

Document 23

Filed 07/25/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

THOMAS SMITH, Defendant.

: : : : : : : : : :

Criminal Action No.08-08-GMS

DEFENDANT'S MOTION TO ATTEND A PRIVATE VIEWING OF SHEILA LAWRENCE, HIS MOTHER Defendant, Thomas Smith, by and through his undersigned counsel, Keir Bradford, Assistant Federal Public Defender, hereby moves this Court for an Order granting him permission to attend a private viewing of Sheila Lawrence, his mother, who passed away on July 22, 2008. In support of this Motion, Mr. Smith avers as follows: 1. Ms. Lawrence's public viewing, funeral mass and burial is currently scheduled for July

30, 2008 at the Bethel Pentecostal Church, located at 23rd and Pine Streets, in Wilmington, Delaware. The House of Wright Mortuary is arranging Ms. Lawrence's funeral services. See Exhibit "A". 2. Mr. Smith is currently in the custody of the United States Marshals Service for the

District of Delaware, and is housed at Salem County Correctional Facility in Woodstown, New Jersey. 3. Mr. Smith respectfully requests the Court's permission to have a private viewing of

his mother on July 29, 2008 at 2:00 p.m.1 in the U.S. Marshal Service's secured sally-port.

Justen Wright, of The House of Wright Mortuary, previously indicated to Mr. Smith's family that this is the funeral home's preferred time to assist in this request. Mr. Smith submits PDF created with pdfFactory Pro trial version www.pdffactory.com

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Case 1:08-cr-00008-GMS

Document 23

Filed 07/25/2008

Page 2 of 2

4.

Shawn Martyniak, Assistant United States Attorney, opposes Mr. Smith's motion.

WHEREFORE, Mr. Smith respectfully requests the Court's permission to have a private viewing of Sheila Lawrence, his mother, on July 29, 2008 at the U.S. Marshal Service's secured sallyport.

Respectfully submitted,

/s/ Keir Bradford Keir Bradford, Esquire Assistant Federal Public Defender 704 King Street, Suite 110 Wilmington, Delaware 19801 (302) 573-6010 [email protected]

Attorney for Defendant, Thomas Smith Dated: July 25, 2008

that an alternative time may be arranged if this time is not convenient for the U.S. Marshals Service. Mr. Wright may be contacted at (302)762-8448. PDF created with pdfFactory Pro trial version www.pdffactory.com

Case 1:08-cr-00008-GMS

Document 23-2

Filed 07/25/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v.

THOMAS SMITH, Defendant.

: : : : : : : : : :

Criminal Action No.08-08-GMS

ORDER

The Court having considered Defendant Smith's Motion to Attend a Private Viewing of Sheila Lawrence, His Mother, and good cause having been shown therefore; IT IS HEREBY ORDERED this day of July, 2008, that the United States Marshal or his

Deputy make arrangements with The House of Wright Mortuary, (302) 762-8448 for a private viewing of the deceased at a mutually agreeable time at the J. Caleb Boggs Federal Building in the secured sally-port of the U.S. Marshals.

Honorable Gregory M. Sleet Chief Judge, United States District Court

PDF created with pdfFactory Pro trial version www.pdffactory.com

Case 1:08-cr-00008-GMS

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Document 23-3

Filed 07/25/2008

Page 1 of 1

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Justen A. Wr;ght, CoF.s.n Vice President

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Wright, 1., L.F.D., C.F.S.P.

This is to inform you that Sheila D~ Lawrence, mother of Thomas Smith passed on July 22, 200e~ Her date of birth is September 11, 1958 and her Funeral will be held on wednesday, July 30, 2008 at Bethel Pentecostal Church, 2300 N. Pine Street, Wilmington, DE with viewing beginning at 9100~M and Funeral at 11:00~M~

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