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:
- Defendant has been charged with Battery – Domestic Violence (M1).
- At initial appearance, the Court ordered that Defendant have no contact with his girlfriend, Jill Smith, the alleged victim in the above-styled cause.
- 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.
- 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.