IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

UNITED STATES OF AMERICA )

)

vs. ) Criminal Case No. 2:06-CR-169-WHA

)

WILMONT TIMOTHY BARNETT )

MOTION FOR RELEASE FROM CUSTODY

COMES NOW Defendant Wilmont Timothy Barnett, by and through counsel, to move

for release from custody pending the trial of this cause. Defendant asserts that there is a

“condition or combination of conditions that will reasonably assure the appearance of the person

as required and the safety of any other person and the community,” within the meaning of 18

USC §3142, the Bail Reform Act of 1984.

Defendant is a native of Chilton County, presently living in Jefferson County. He has

long-standing ties to the Clanton community; his mother and other family members live in

Chilton County. If permitted to remain free of detention, he would live with his wife and five

children. He is not a flight risk.

Defendant’s prior convictions were for drug-related offenses, not for crimes of violence,

and the present charge does not allege any violent behavior. He does not pose a danger to the

safety of any person.

Defendant has cooperated with law enforcement personnel in this case.

Defendant proposes the following release plan and conditions:

1. Defendant agrees to such electronic monitoring as may be required. He agrees to remain

in his home except when permitted to go to work, to church (Morning Star Baptist

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Church in Clanton), to court, to meet with his lawyer, or to any other places or events as

approved in advance by his pretrial services officer..

2. Defendant agrees to move from his residence in Birmingham, Alabama, to the residence

of his mother, Deborah Wright, in Clanton, Alabama, so as to remain at all times within

the Middle District of Alabama.

3. Defendant will reside in Clanton with his wife, Stephanie Barnett, and his five children.

4. Defendant agrees to maintain gainful employment with Independent Fence and Storage in

Clanton under the supervision of Michael Deason. Defendant’s normal work hours are

expected to be 7:00 a.m. - 5:00 p.m., subject to weather conditions.

5. Defendant agrees to refrain from use of alcoholic beverages and controlled substances,

and he agrees to such drug testing as may be directed by his pretrial services officer.

6. Defendant agrees to contact his pretrial services officer by telephone on a daily basis and

appear in person as required.

7. Defendant agrees to continue attending services at Morning Star Baptist Church in

Clanton every Sunday.

8. Defendant agrees to execute a $25,000.00 signature bond.

WHEREFORE, the premises considered, Defendant prays that the Court will overrule the

government’s motion for detention and will order Defendant released pending further

proceedings in this case.

RESPECTFULLY SUBMITTED, this __1st__ day of March, 2007.

/s/ JAY LEWIS

Law Offices of Jay Lewis, L.L.C.

P.O. Box 5059

Montgomery, Alabama 36103

(334) 263-7733 (Voice)

Case 2:06-cr-00169-WKW-SRW Document 95 Filed 03/01/2007 Page 2 of 3
(334) 832-4390 (Fax)

J-Lewis@JayLewisLaw.com

ASB-2014-E66J

Attorney for Defendant

CERTIFICATE OF SERVICE

I hereby certify that on the _1st_ day of March, 2007, I electronically filed the foregoing

with the Clerk of the Court using the CM/ECF system which will send notification of such filing

to the following parties or counsel:

A. Clark Morris

Office of the United States Attorney

One Court Square, Suite 201

Montgomery, AL 36104

/s/ JAY LEWIS

Law Offices of Jay Lewis, L.L.C.

P.O. Box 5059

Montgomery, Alabama 36103

(334) 263-7733 (Voice)

(334) 832-4390 (Fax)

J-Lewis@JayLewisLaw.com

ASB-2014-E66J

Attorney for Defendant

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