IN THE DISTRICT COURT OF THE UNITED STATES
FOR THE DISTRICT OF SOUTH CAROLINA
UNITED STATES OF AMERICA ) CR. NO.:
-vs- ) MOTION TO DELAY REPORTING
) DATE FOR THE BUREAU
) OF PRISONS
Now comes the defendant, ___________________, by and through his undersigned
attorney, ___________, who respectfully moves the Court to delay the date for the commencement
of his sentence of imprisonment. On May 00, 2000, the defendant received a sentence of 00 months
imprisonment for violation of 18 U.S.C. ' 0000 (use of the internet to persuade a person under the
age of 18 to engage in sexual activity. The defendant has been designated to FCI Butner and is to
report on August 00, 2000. (letter attached).
At sentencing, the defendant introduced documentation that established he was the
primary care giver for his wife (attached). The wife suffers from a number of medical disorders that
have left her totally disabled and unable to care for herself. She has a history of serious illness. The
defendant requested commencement of his sentencing be delayed until such time as his wife could be
admitted to a nursing home for care. The court instructed the defendant to make his best efforts to
get his wife into a nursing home immediately and come back to the court if he was unsuccessful in
getting her admitted prior to his reporting date.
Since his sentencing date, the defendant has made substantial good faith efforts to arrange for
care of his wife while he is incarcerated. He has given up his home and put most of their belongings
in storage. The defendant and his wife have moved to an extended stay facility in _____, South
Carolina, and he has contacted at least a dozen nursing homes in the upstate of South Carolina
seeking the admittance of his wife. All have put her on their waiting lists with estimated times of
admittance from three months up to two years. (Letters attached from several nursing homes). the
defendant has been informed that it is much more difficult to get a medicare bed in a nursing home
than a private pay bed. The medicare beds that are available go first to patients who are entering the
nursing home following release from a three-day minimum stay in a hospital.
The defendant is reasonably sure that if his reporting date were postponed until
_____________, 2008, he would be able to secure a bed in a suitable facility for his wife. Therefore,
the defendant respectfully requests that his reporting date be continued until that time.
Assistant United States Attorney __________________has been consulted and states that he
would leave this decision to the discretion of the Court.
Attorney for the Defendant
, South Carolina