DEFENDANT, by and through the undersigned counsel, requests that this Honorable Court enter an Order modifying the conditions of his release from incarceration.  As grounds for this Motion, Defendant states as follows:

  1. Defendant has been charged with Battery - Domestic Violence (M1).
  2. At initial appearance, the Court ordered that Defendant have no contact with his girlfriend, Jill Smith, the alleged victim in the above-styled cause.
  3. Ms. Smith has requested that undersigned counsel apply for modification of Defendant’s release conditions in order to rescind the “no contact” order and allow for consensual contact.
  4. The current “no contact” order imposes a hardship on both Defendant and Ms. Smith, and Ms. Smith does not fear for her safety or well-being with regard to Defendant.

WHEREFORE, the undersigned counsel respectfully requests that this Honorable Court grant this motion and rescind the “no contact” provision previously ordered by the Court.